logoPASSAIC PARTNERS®

Passaic Partners Privacy Policy

Effective Date: April 2026
Last Updated: April 2026

Passaic Partners LLC (“we,” “us,” or “our”) is an institutional asset manager committed to safeguarding the confidentiality and security of the information entrusted to us. We operate under applicable regulatory frameworks, including oversight by the U.S. Securities and Exchange Commission (“SEC”) and, where applicable, the Commodity Futures Trading Commission (“CFTC”) and National Futures Association (“NFA”).

This Privacy Policy describes how we collect, use, disclose, and protect information obtained through our website and related services.

1. Scope of This Policy

This Privacy Policy applies to information collected through our website (passaicpartners.com) and digital services that link to this Policy. It does not apply to information collected offline or through other channels unless expressly stated.

2. Information We Collect

a. Information You Provide Voluntarily
We may collect personal information that you voluntarily provide, including:

  • Name, title, employer, and professional affiliation
  • Contact details (email address, phone number, mailing address)
  • Information submitted through contact forms, investor inquiries, or subscription requests

b. Automatically Collected Information
We may automatically collect certain information about your device and interaction with our website, including:

  • IP address (which may be truncated or anonymized where required)
  • Browser type and version
  • Device identifiers
  • Pages viewed, time spent, and referring URLs

c. Cookies and Tracking Technologies
We use cookies and similar technologies to enhance functionality, analyze usage, and improve performance. You may control cookies through your browser settings; however, disabling cookies may affect website functionality.

3. Use of Google Analytics

We use Google Analytics, a web analytics service provided by Google LLC, to better understand how visitors interact with our website.

Google Analytics uses cookies and similar technologies to collect and analyze information about website usage. This information may include:

  • Pages visited and user interactions
  • Device and browser information
  • IP address (processed in accordance with applicable privacy laws)

We have configured Google Analytics to support IP anonymization where applicable. Data collected may be transmitted to and stored on servers in the United States or other jurisdictions.

You can learn more about how Google uses data here: https://policies.google.com/privacy

You may opt out of Google Analytics tracking by using the Google Analytics Opt-out Browser Add-on.

4. How We Use Information

We use information for legitimate business and regulatory purposes, including:

  • Responding to inquiries and providing requested materials
  • Managing relationships with institutional investors and prospective clients
  • Operating, maintaining, and improving our website
  • Monitoring usage patterns and website performance
  • Ensuring compliance with applicable laws, rules, and regulations
  • Detecting and preventing fraud, cybersecurity threats, or misuse

5. Legal and Regulatory Basis

Where required by applicable law, we process personal information on the basis of:

  • Legitimate interests, including business development and website optimization
  • Compliance with legal and regulatory obligations, including those imposed by the SEC, CFTC, and NFA
  • Consent, where required
  • Performance of contractual or pre-contractual obligations

6. Disclosure of Information

We do not sell personal information. We may disclose information:

  • To affiliates and related entities
  • To third-party service providers (e.g., hosting providers, analytics vendors) under appropriate confidentiality and data protection obligations
  • To regulatory authorities, including the SEC, CFTC, and NFA, or to courts and governmental bodies as required by law or regulation
  • In connection with mergers, acquisitions, or other corporate transactions

7. Data Security

We maintain administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, disclosure, alteration, or destruction. These measures are consistent with industry standards and regulatory expectations applicable to SEC-registered and NFA-member firms.

8. Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this Policy, including complying with legal, regulatory, and recordkeeping obligations applicable to investment advisers and commodity pool operators or trading advisors, as relevant.

9. International Data Transfers

Information collected may be transferred to and processed in the United States and other jurisdictions where data protection laws may differ from those in your country of residence.

10. Your Rights

Depending on your jurisdiction, you may have rights including:

  • Access to personal information
  • Correction or deletion of personal information
  • Restriction or objection to processing
  • Data portability
  • Withdrawal of consent (where applicable)

Requests may be submitted using the contact details below.

11. California Privacy Rights

If you are a California resident, you may have rights under the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”), including:

  • The right to know what personal information is collected and how it is used
  • The right to request deletion (subject to legal exceptions)
  • The right to correct inaccurate information
  • The right to limit certain uses of sensitive personal information

We do not sell or share personal information as defined under California law.

12. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for their privacy practices or content.

13. Updates to This Policy

We may update this Privacy Policy periodically. Updates will be posted on this page with a revised “Last Updated” date.

14. Contact Us

If you have questions about this Privacy Policy or our data practices, please contact:

Passaic Partners LLC
110 Edison Place, Suite 304
Newark, NJ 07102
info@passaicpartners.com
201.603.7200

Important Notice
This website is intended solely for institutional investors and other qualified persons. It is not intended for retail investors or for distribution in jurisdictions where such use would be contrary to applicable law or regulation.

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