Privacy Policy

1. Who we are and what this notice covers

This Privacy Policy sets forth the privacy practices of Embassy Asset Management LP (“Embassy,” “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 Embassy that conditions your use of the Site, where and as permitted by applicable law.

2. What this notice does not cover

This Privacy Policy applies to this website and to other communications with Embassy. It does not describe how we handle the personal information of individuals who engage with Embassy to obtain financial products or services.

If you are an investor in an Embassy private fund, you receive a separate privacy notice pursuant to the Gramm-Leach-Bliley Act and Regulation S-P that describes how nonpublic personal information about you is collected, used, disclosed and protected in connection with your investment. If you are a shareholder of an Embassy mutual fund described on the Site (each, a “Fund”), Embassy does not deliver a privacy notice to you. This Privacy Policy also does not apply to information collected by the Funds’ distributor, transfer agent, administrator or any financial intermediary through which you hold Fund shares. Those firms maintain their own privacy notices, which govern the handling of your information by the firm that provides them.

3. Information we collect

Information you give us. If you contact us, request information, or complete a form on this website, we collect the information you provide, which may include your name, your firm, your title, your email address, your telephone number, your postal address and the substance of your message.

Communications. We collect information provided to us in any exchange with you, including when you contact us with questions, feedback, or otherwise.

Information collected automatically. When you visit this website we automatically collect information about your device and your visit, including your IP address, approximate location derived from that IP address, browser type and version, operating system, device identifiers, referring and exit pages, the pages and documents you view, the links you click, the dates and times of your visits, the duration of your visits, and whether you have opened our marketing emails or clicked links within them.

Information from third parties. We receive information about visitors to this website from third-party data providers, including visitor identification service providers. We may also receive information from publicly accessible sources, from professional networking and business information databases, and from service providers engaged to support our marketing and business development. You or the platforms may provide us with information through the third party platforms, and we will treat such information in accordance with this Privacy Policy.

4. Cookies, tracking technologies and visitor identification

Cookies are small text files placed on your device by a website. We use cookies, web server logs, pixels, tags and similar technologies on this website.

The categories of cookies and similar technologies we use are:

• Strictly necessary. Required for the website to function, including page delivery, security, load balancing and remembering your cookie choices. These cannot be switched off, although you can block them in your browser, in which case parts of the website may not work.
• Performance and analytics. Help us understand how visitors use the website so we can improve it.
• Remember choices you make, such as a selected date range on a performance chart, so the website behaves consistently during and between visits.
• Targeting, advertising and visitor identification. Record your visit, the pages you view and the links you follow, and are used to identify you and to deliver and measure marketing.

Visitor identification. We use a third-party service that matches information about your visit, including your IP address and device characteristics, against other data sources to identify you by name and business contact information, even if you never contact us. The provider acts as an independent business and may use that information for its own purposes. Because this works from network and device information rather than cookies, declining or deleting cookies will not prevent it. To opt out, use the provider’s opt-out at https://app.retention.com/optout.

We may also combine personal information we receive from you with personal information we obtain from sources such as financial advisers, consumer reporting agencies, consultants, and custodians.

We may include pixels or web beacons in emails and newsletters we send. These tell us whether a message has been opened and which links were followed, and they help us tailor our communications. Instructions for unsubscribing are included in every marketing email.

Managing cookies

You can accept or decline non-essential cookies using the cookie notice that appears when you first visit this website. You can also set your browser to notify you when cookies are set, to refuse cookies, or to delete cookies already stored on your device. If you block or delete cookies, some parts of this website may not function as intended, and you will need to set your preferences again on each browser and device you use.

5. How we use personal information

We use personal information to operate, maintain, secure and improve this website; to respond to your enquiries and provide information you request; to communicate with you, including to send you communications about our Funds and services where permitted; to understand who visits the website and how it is used; to conduct market research and business development, including sending you direct marketing communications; to comply with legal, regulatory and self-regulatory obligations; to prevent, detect and investigate fraud and unlawful activity; and to establish, exercise or defend legal claims or disputes.

6. How we disclose personal information

We disclose personal information to service providers that support this website and our business, including hosting, analytics, visitor identification, email, customer relationship management, marketing and professional services providers, each of which is required to protect the information and to use it only for the purposes for which it is disclosed to them.

We make information about visits to this website available to the visitor identification service described in section 4, which uses that information as an independent business rather than on our behalf.

We disclose personal information to our affiliates in connection with our business and to our professional advisers.

We disclose personal information to regulatory, self-regulatory, administrative, tax and law enforcement authorities where required or where we consider it appropriate, and to a court or other tribunal in connection with legal process.

We may disclose personal information in connection with a corporate transaction, including a merger, acquisition, reorganization, financing or sale of assets, and where we consider disclosure necessary or appropriate to prevent harm or financial loss, to protect our operations, or to establish or protect our rights, privacy, safety or property, or those of our affiliates, you or others.

7. Retention

We retain personal information as necessary to fulfil the purposes for which it was collected and processed, in accordance with our policies and with applicable laws, based on factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, and the purposes for which we use personal information.

8. Your choices and your state privacy rights

Marketing. You may opt out of marketing-related communications by following the opt out or unsubscribe instructions contained in the marketing communication we send you or by contacting us using the details in the Contact us section of this Site.

State privacy rights. Depending on where you live, and subject to exceptions and verification requirements under applicable law, you may have the right to: confirm whether we process personal information about you and access that information; obtain a copy of it in a portable format; correct inaccurate personal information; request deletion of personal information; opt out of the sale or sharing of personal information, of targeted advertising, and of certain profiling; limit the use and disclosure of sensitive personal information; and not be discriminated against for exercising any of these rights. To make a request, please email us at legal@embassyfunds.com. We may ask for specific information from you to help us confirm your identity. Depending on your jurisdiction, you may be entitled to empower an “authorized agent” to submit requests on their behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. You are entitled to exercise the rights described above free from discrimination.

Limits on your choices. Your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. If you are not satisfied with how we address your request, you may submit a complaint by contacting us as provided above.

Complaints. If you are based in certain jurisdictions, you may lodge a complaint about how we handle your personal information with a supervisory authority, including in your country of residence, place of work, or where you believe an incident took place.

California Shine the Light. California residents may request information about personal information disclosed to third parties for those third parties’ direct marketing purposes. We do not disclose personal information to third parties for their own direct marketing purposes.

9. Security

We maintain physical, electronic and procedural safeguards designed to protect personal information. No system is completely secure, however, and we cannot guarantee the security of information transmitted to or from this website. Transmission is at your own risk.

10. Children

This website is not directed to children and we do not knowingly collect personal information from anyone under 18 through this website. If you believe a child has provided us with personal information, contact us at legal@embassyfunds.com and we will delete it.

11. Visitors outside the United States

This website is published in the United States and is intended for residents of the United States. It is not directed at persons in any jurisdiction where its publication or availability would be contrary to local law or regulation. If you access this website from outside the United States, you do so on your own initiative, and you understand that the personal information we collect will be transferred to, stored in and processed in the United States, where data protection law differs from the law of your own country and where you may not have the same rights.

12. Third-party websites

This website links to websites operated by third parties, including the Funds’ document repository and the SEC’s website. We do not control those websites and are not responsible for their content or their privacy practices. Review the privacy notice of any website you visit.

13. Changes to this Privacy Policy

We may change this Privacy Policy at any time. The date at the top of the page shows when it was last updated. Material changes will be posted on this page, and your continued use of the website after a change is posted means you are aware of the current version.

14. 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. 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 policies.

15. Contact us

If you have any questions, comments or complaints about this Privacy Policy, our privacy practices, or if you would like to exercise your rights with respect to your personal information, please contact us by email at legal@embassyfunds.com or write to us at

Embassy Asset Management LP

1200 Morris Turnpike, Suite 3005

Short Hills, New Jersey 07078