Privacy Policy

Effective Date: July 25, 2019

This Privacy Policy (defined as follows) describes how Vision Hill Group, LLC and its subsidiaries and affiliates (collectively, “Vision Hill” “we,” “our” or “us”) collects, uses, and discloses Personal Information (defined below) about individuals (collectively, “users” or “you”) receiving our products and services, exploring or maintaining a business relationship with us (either directly or through an intermediary) and/or using the Vision Hill website (, online features or database (the “Site” or “Sites”) and the services, features, content or applications offered by Vision Hill (the “Services”) (all together the “Privacy Policy’). As used in this Privacy Policy, Personal Information means any information relating to an identified or identifiable natural person (“Personal Information”); Personal Information is intended to cover all information subject to personal data processing and privacy laws applicable to our business.

The Privacy Policy also describes your rights, where applicable, and how to exercise them. You may contact us at any time with questions related to our Personal Information processing and privacy via email at

This Privacy Policy covers the treatment of “Personal Information” gathered when you are using or accessing the Services. This Privacy Policy also covers our treatment of any Personal Information that our business partners share with us or that we share with our business partners. Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not use, browse, provide or utilize any information on the Site or Services. By using the Site and Services in any way, you agree to this Privacy policy. This policy may change from time to time. Your continued use of the Site or Services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

We only collect information from you or about you that is reasonably necessary for us to provide the relevant product or Services, business relationship and/or communication, consistent with the nature of such product, service, relationship or communication. Based on the specific products, Services, business relationship or Sites involved as well as requirements under applicable law, we may collect the following categories of Personal Information from you or your representative:

Account Information:

When you create an account, you will provide information that could be Personal Information, such as your name, password and email address. You acknowledge that this information may be personal to you, and by creating an account on the Site and providing Personal Information to us, you allow others, including us, to identify you and therefore may not be anonymous. We may use your contact information to send you information about our Services or as otherwise described in this Privacy Policy.

Investment Manager Information:

When you contribute information to Vision Hill either through the use of the Site or directly in communication with Vision Hill, you will provide information related to your firm such as names of key personnel, addresses, emails, contact information, AUM, inception dates, strategy types, fund information, performance data, due diligence related information and other data.

User Contributions and Content:

All content added, created, uploaded, submitted, distributed, or posted to the Site by users (collectively “User Content”), whether publicly posted or privately submitted to Vision Hill directly is your sole responsibility and you consent to its accuracy and its use by Vision Hill to provide its products and Services. You may provide information or contribute content to be published or displayed on public or private areas of the Site and Services.

We may also collect any of the following information: name, email address, telephone number, mailing address, company name, title or position, business contact information, username and password, any other personal or company information you or your company or firm representative provides on our Site or Services or directly in communication with Vision Hill.

When you access and use the Site and Services, we may automatically collect certain details of your access to and use of the Site and Services, including traffic data, location data, logs and other communication data and the resources that you access and use on or through the Site and Services.

Neither the Site nor the Services is intended for children under 13 years of age, and we do not knowingly collect Personal Information from children under 13. None of our Sites or Services are targeted for use by children under 13. We do not target any of our products or Services or Site content/features for use by children under 13 years of age.

We use the information that we collect about you or that you provide to us, including any Personal Information, to:

  • Provide you with the Services and its contents, access the Site and its contents, and any other information, products or other services that you request from us.
  • Fulfill any other purpose for which you provide it.
  • Give you notices about your account.
  • Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • Provide you with our Services and products and communicate with you about your (or your employer’s/represented company’s) account or use of our products, Services and/or Sites.

Often due to the nature of the product or service involved or the context in which the Personal Information is used, it will be apparent how we intend to use the information. Additional information about processing related to a particular product or service may be separately posted on the relevant Site or contained in the applicable terms and conditions.

We may disclose aggregated information about our users, and information that does not identify any individual, company, or firm, without restriction, unless you have withdrawn such consent when providing us with the information.

From time to time, to the extent permitted by applicable law and subject to any contractual limitations on sharing Personal Information set forth in a relevant contract for products and Services, we may share your information with our affiliates, subsidiaries, business partners, clients (such as where we process your Personal Information in connection with your role with your employer), third party service providers and authorities in the following circumstances:

Affiliates, Subsidiaries, Business Partners and Clients. We may share your information with our affiliates, subsidiaries, business partners, and clients in the US and worldwide. To the extent required or permitted by applicable law, by visiting or using our Site or otherwise providing us with your information, you consent to this sharing of your information. Where such consent exists, to opt-out of such sharing, please contact us via email at

Service Providers. We may share your information with third parties who perform functions on our behalf (e.g., hosting or operating our Services or Sites, sending email marketing communications, or data analysis). We do not authorize these third parties to use your information for purposes other than for which it has been provided, and we do not authorize these third parties to disclose that information to unauthorized parties. We require these third parties to maintain appropriate security to protect your information from unauthorized access or processing.

As Required or Appropriate by Law. We may disclose your information to regulatory authorities, courts, and government agencies where we believe that doing so would be in accordance with or permitted or required by any applicable law, regulation or legal process, to defend the interests, rights, and/or property of Vision Hill, or to respond to emergencies.

Business Transfers. We may transfer your information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, brands, affiliates, subsidiaries or other assets. To the extent permitted by applicable law, we may share information with a prospective buyer or transferee of the business as part of the diligence process provided that we require any such third party to maintain the confidentiality of your information and protect it with appropriate technical and organizational security measures.

We may share your information with other third parties as directed by you or subject to your consent. We may also share and otherwise process aggregated information or de-identified information that does not identify you individually with other third parties. We also use this aggregated or de-identified information for Vision Hill’s and its affiliates’ various business purposes, including the creation and sale of other products and services to our clients and potential clients. This aggregate or de-identified information is not traceable to any particular client or user and will not be used by a third party to contact you.

We do not share, sell, rent or trade the personal information you provide through our Site or directly to Vision Hill in private communications to our service providers or business partners for their own direct marketing purposes, unless we have explicitly given you the option to opt-in or opt-out of such disclosures. The foregoing restriction does not apply to information provided by those firms voluntarily contributing data for inclusion in our databases, indices, quarterly and monthly benchmark reports, and other data products. Any direct sharing of Personal Information, contact information, firm information and data, and performance or due diligence information will be considered as providing consent for Vision Hill to use such information and data for Vision Hill’s own purposes. Where such consent exists, to opt-out of such sharing, please contact us via email at For more information on data contribution, please reach out to us at the aforementioned email address.

To the extent required by applicable law, in our capacity as the controller of your Personal Information, we will also provide you with the opportunity to be informed of whether we are processing your Personal Information and at any time to access, correct, update, oppose, delete, block, limit or object to our use of your Personal Information. The foregoing rights will be afforded to you free of charge (except to the extent that your requests are manifestly unfounded or excessive, in which case, we may charge an administrative fee or refuse to meet your request). Please note that legal obligations that apply to our business may prevent us from immediately deleting parts of your information. To exercise your rights, please contact us as detailed below.

Access to your Personal Information. This means that you have the right to request information on our use of your Personal Information. You also have the right to request a copy of the Personal Information being processed at no cost. However, we may charge you a reasonable administrative fee to provide you with additional copies of the Personal Information. If you make your access request by electronic means such as email, we will provide you with the information in a commonly used electronic format.

Rectification of your Personal Information. We will at your request, or at our own initiative, rectify, anonymize, erase or complement Personal Information that you or we discover is inaccurate, incomplete or misleading. You also have the right to complete the Personal Information with additional data if relevant information is missing.

Erasure of your Personal Information. You have the right to request that we erase your Personal Information if we no longer have an acceptable reason for processing the data. Given this, erasure shall be made by us if:

  • the Personal Information is no longer necessary for the purposes for which it was collected;
  • we use your Personal Information with your consent and you withdraw your consent;
  • you object to the processing of your Personal Information based on our legitimate interest and there is no overriding legitimate ground for the processing;
  • the Personal Information has not been lawfully processed;
  • we are required to erase the Personal Information due to a legal obligation; or
  • you are a child and we have collected the Personal Information in relation to the offer of information society services.

However, there might be requirements under applicable law, or other compelling reasons, that prevents us from immediately erasing your Personal Information. In such case, we will stop using your Personal Information for any other reason than to comply with the applicable law, or the relevant compelling reason.

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure.

We take reasonable technical, administrative and physical security measures to protect your Personal Information, including applying generally accepted industry standards to protect the information submitted to us during transmission and once we receive it. However, no method of transmission over the internet, or method of electronic storage is 100% secure, so we unfortunately cannot guarantee absolute security.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site or Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Site or Services.

Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted through our Site or Services. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide. If you have reason to believe that your interaction with us is no longer secure (e.g., if you feel that the security of any account you might have with us has been compromised), please contact us immediately.

The technologies we use for automatic information collection may include:

Cookies (or mobile cookies). A cookie is a piece of data stored on a site visitor’s hard drive to help us improve your access to our site and identify repeat visitors to our site. For instance, when we use a cookie to identify you, you would not have to record your language preference more than once, thereby saving time while on our site. Cookies can also enable us to track and target the interests of our users to enhance the experience on our site. Usage of a cookie is in no way linked to any Personal Information information on our site.

Web Beacons. Pages of the Site and Services and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit Vision Hill, for example, to count users who have visited those pages or opened an email and for other related Site and Services statistics.

We may update our Privacy Policy from time to time. If we make material changes to how we treat our users’ Personal Information, we will post the new Privacy Policy on this page with a notice that the Privacy Policy has been updated.

The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for visiting this Privacy Policy each time you use the Site or Service to check for any changes.

If you have any questions about this Privacy Policy or about our privacy practices, please contact us by email at