Celeres Capital Advisors LLC Privacy Policy 

Celeres Capital Advisors LLC, together with its subsidiaries and affiliated companies (collectively, “Celeres”) is committed to protecting your privacy. 

This Privacy Policy applies to the desktop and mobile versions of www.celerescapital.com (the “Site”), which provide information about Celeres and its investment strategies. References herein to “we,” “us,” or “our” are references to Celeres. “You” and “your” refers to anybody using the Site.  Please see the Celeres Capital Advisors ADV for the firms Privacy Policy. 

This Privacy Policy describes the kinds of information we may gather during your visit to the Site, how we use your information, and how we protect your information. This Privacy Policy only applies to information we may collect from visitors to the Site or that visitors to the Site may provide through the Site. It does not apply to information we collect through other means, including, but not limited to, information transmitted to us via email or provided in subscription documents in connection with investments in our funds or managed accounts. Investors in Celeres managed funds or accounts should refer to their relevant governing documents (e.g., subscription agreement, advisory agreement) for the applicable privacy notice. 

By visiting the Site, you consent to us collecting and storing your information as described in this Privacy Policy. Please read this Privacy Policy carefully. If you do not agree to this Privacy Policy, please do not use the Site. 

We may revise this Privacy Policy from time to time. We will post any changes on this page and update the date at the top, so be sure to check back periodically to stay aware of any modifications. Your continued use of the Site after changes have been posted will constitute your acceptance of this Privacy Policy and any changes. 

Information We Collect 

Depending on your use of the Site, we may collect information from you in different respects. 

Personally Identifiable Information 

Personally Identifiable Information (“PII”) refers to information that can be used to identify you. We consider this information highly confidential. Depending on your use of the Site, we may collect the following information directly from you: 

• We may collect your name, email address, and any additional information you provide if you fill out the “Contact Us” form on the Site. 

Cookies and Technical Information 

We also collect certain technical information through automatic means. For example, we use cookies and other technologies to collect certain information when you use the Site. Cookies are text files containing small amounts of information which are downloaded to your device or hard drive when you visit a website, which may include an anonymous identifier. Cookies are then sent back to the originating web domain on your subsequent visits to that domain. There are two general categories of cookies: (1) session cookies that are deleted automatically when you close your browser, and (2) persistent cookies that remain on your device after the browser is closed. 

The information collected by the Site in this manner may include IP address, browser type, operating system, referring URLs, content viewed, dates and times of site visits, and other similar analytics. These analytic cookies generate aggregate statistics that are not associated with an individualized profile. 


Celeres uses Google Analytics to provide data on usage of the Site. We may also collect information through certain Google Analytics advertising features, specifically Remarketing and Advertising Reporting Features. These features can help make advertising potentially relevant to your interests. 

The Site does not currently respond to web browser “do not track” signals. You can manage or disable cookies at any time by adjusting your browser settings. Browsers are different, so please refer to the settings menu of your browser for instructions on how to change your cookie preferences. For information on how to disable Flash cookies, please visit www.adobe.com/products/flashplayer/security. You can visit www.google.com/settings/ads to manage the Google ads you see and opt out of ad personalization. Additional information on cookies can be found at www.allaboutcookies.org. Please note that if you choose to disable cookies, the Site may not function properly and certain services may not be available to you. 

How We Use the Information We Collect 

We collect and use your information to provide and manage the services you request, including to respond to an inquiry you initiated via a form on the Site. We may periodically contact you with information about our services, legal notices, or other important information. We may also use your information collected via cookies to help tailor advertising to your interests. 

We may use third-party service providers (such as website hosting providers, analytics providers) or other third-party organizations helping to support our business that may collect, store, or process your information on our behalf. We do not sell your information and have not done so at any time during the 12 months prior to the date of this Privacy Policy. 

We may also share your information in the event that it is necessary for any of the following reasons: 

• To administer and improve the Site and develop new products and services; 

• To protect our rights or property or the safety of our employees or others; 

• To comply with any court order, legal process, or respond to any governmental or regulatory request; or 

• To transfer information in the event of a merger, transfer of assets, or other organizational restructuring. 

Children’s Privacy 

The Site is not intended for and is not directed to children under 13 years of age. We do not knowingly collect or store any personal information from children under 13 years of age. If you are under 13 years of age, do not provide personal information to us and do not use the Site. 

International Users 

We are based in the United States in the Commonwealth of Puerto Rico. This Privacy Policy is provided in accordance with applicable US law. If you decide to continue to access the Site from a location outside the United States, you hereby agree that such use is subject to this Privacy Policy and that your personal information may be internationally transferred, stored or processed in the United States. Please do not use this Site if the transfer of your personal information to the United States violates the law of your jurisdiction. 

Links to Third-Party Websites 

The Site may contain links to other websites. We have no control over and are not responsible for the privacy policies or practices of such sites. Whenever you link to another website, you may be asked to provide login credentials or other information. Please note that any PII or other information you disclose to third parties, including any third-party website linked from the Site, is subject to the privacy customs and policies of those third parties. 

Information Security 

We maintain appropriate administrative, technical, and physical controls designed to protect your personal information against loss or accidental, unlawful or unauthorized, alteration, access, disclosure or use. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure, and we therefore urge you to always use caution when transmitting information over the Internet. If you have reason to believe that your interaction with us is no longer secure, please notify us immediately using the contact information below. 

Your Privacy Rights 

Pursuant to various state laws (such as the California Consumer Privacy Act/California Privacy Rights Act), you may have the right, subject to certain limitations, to: (i) request access to PII we hold about you; and (ii) request that we delete your PII. You may also have the right request the categories of personal information we have collected about you, the categories of sources where we collected such personal information, the purpose for such collection, and the categories of third parties (if any) with which we have shared such personal information for a business purpose. 

All requests should be made using the contact details set out in the “Contact Us” section below. Please note that if you request that your PII be deleted, you may no longer be able to access or use certain parts of the Site or receive responses to inquiries. We will respond to your request in writing, or orally if requested, as soon as practicable and consistent with applicable law. We may request proof of identification to verify your request before acting upon it. For more details in relation to your rights, including how to exercise them, please contact us using the contact details set out in the “Contact Us” section below. 

We are committed to providing you with control over your personal information. If you exercise any of the rights explained in this Privacy Policy, we will not disadvantage you or discriminate against you. 

We do not disclose your PII to third parties for the third parties’ direct marketing purposes. 

For additional information regarding our collection and use of personal information, please see “Information We Collect” and “How We Use the Information We Collect” above. 

Contact Us 

Your privacy and the security of your personal information are important to us. Please contact admin@celerescapital.com with any questions related to this Privacy Policy. 

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Celeres Capital Advisors LLC California-Specific Privacy Policy

The California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA), imposes certain obligations on Celeres Capital Advisors LLC, together with its subsidiaries and affiliated companies (together, “Celeres,” “we” or “us”) and grants certain rights to California residents (“California Resident,” “you” or “your”) with regard to “personal information.” If you are a California Resident, please review the following information about our privacy practices surrounding how and why we collect, use, disclose and share personal information and your potential rights with regard to your personal information under the CCPA. The rights described herein are subject to exemptions and other limitations under applicable law.

This California-Specific Privacy Policy applies to the desktop and mobile versions of www.celerescapital.com (the “Site”), which provide information about Celeres and its investment strategies. Terms used herein have the meaning ascribed to them in the CCPA. We are a “business.”

Notice at Collection and Use of Personal Information

Information We Collect

Depending on how you interact with us, we may collect certain categories of personal information from or about a California Resident, including:

  • Identifiers and similar information such as, name, address, date of birth, email address, social security number, driver’s license number, passport number, online identifiers (like IP address) or other similar identifiers;

  • Additional information subject to Cal. Civ. Code § 1798.80(e), such as your education, credit card number, state identification card number, signature, bank account, or other financial information;

  • Characteristics of protected classifications under certain federal or state laws, including, gender, national origin, or marital status;

  • Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing histories or tendencies, including funds invested, investments considered, or sources of wealth;

  • Audio (e.g., voicemail), electronic, visual or similar information 

  • Internet or other electronic network activity information, including interactions with our website (e.g., browsing history, cookies) or use of certain online tools;

  • Professional or employment-related information, including occupation, compensation, employer, and title; and

  • Inferences drawn from any of the information identified above to create a profile reflecting your preferences or similar information, including your potential interest in investing in new funds.

How We Use Collected Information

We may use your personal information for our business or commercial purposes, such as but not limited to:

  • Performing services on behalf of a fund or investment vehicle, including maintaining or servicing accounts, providing investor relations services, processing subscriptions, and withdrawals; verifying information, processing payments or providing similar services;

  • Performing our contractual obligations to a California Resident, such as an investor or client, including providing updates on performance, providing tax reporting and other operational matters;

  • Detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity, including preventing fraud and conducting “Know Your Client,” anti-money laundering, terrorist financing, and conflict checks; and

  • Enabling or effecting commercial transactions, including, using bank account details to remit funds and process distributions.

  • Improving website functionality and user experience.

  • Responding to inquiries submitted via the Site.

For more information about our privacy practices, please review our entire Celeres Capital Advisors LLC Privacy Policy, which is available here.

Our Collection, Use, Disclosure, and Sharing of Personal Information

Information We Have Collected

In the preceding 12 months, and depending on how you interact with us, we may have collected the categories of personal information listed above in the “Information We Collect” section.

Sources of Personal Information

We may collect personal information about you directly from you and/or your intermediaries through sources such as:

  • Account applications, subscription agreements, advisory agreements, and other forms or related documentation;

  • Written, electronic, or verbal correspondence with us or our service providers;

  • Investor or client transactions;

  • An investor’s or client's brokerage or financial advisory firm, financial advisor, or consultant; and/or

  • From information captured on applicable websites (e.g., via cookies or contact forms).

In addition, we may collect personal information from different sources, such as:

  • Our affiliates, our service providers, or our affiliates’ service providers;

  • Public websites or other publicly accessible directories and sources, including bankruptcy registers, tax authorities, governmental agencies and departments, and regulatory authorities; and/or

  • From credit reporting agencies, sanctions screening databases, or from sources designed to detect and prevent fraud.

Purposes for Collecting Personal Information

We may collect your personal information for the business or commercial purposes described above in the “How We Use Collected Information” section.

Our Disclosure and Sharing of Personal Information

We do not sell your personal information, and we do not share your personal information for cross-context behavioral advertising.

In the preceding 12 months, we may have disclosed for a business purpose the following categories of personal information to the following categories of third parties, as described in the following chart:

Category of Personal Information Disclosed

Category of Third Party

Identifiers (e.g., name, address, email, SSN, online ID)

Service Providers (Administrator, IT, CRM, Email), Counterparties/Intermediaries, Custodians, Auditors, Legal Counsel, Regulators, Financial Institutions, Fraud Prevention Services

Additional info per Cal. Civ. Code § 1798.80(e) (e.g., signature, bank info)

Service Providers (Administrator, Custodian), Financial Institutions, Counterparties, Regulators

Commercial information (e.g., investment history)

Example: Service Providers (Administrator), Auditors, Legal Counsel, Regulators

Internet/Network activity (e.g., website usage)

Service Providers (Website Host, Analytics Provider)

Professional/Employment info (e.g., occupation, title)

Service Providers (KYC/AML checks), Regulators

In addition, in the preceding 12 months, we may have disclosed for a business purpose all of the categories of personal information identified in “Information We Collect” above, to the following categories of third parties: (i) judicial courts, regulators, or other government agents purporting to have jurisdiction over us, our subsidiaries or our affiliates, or opposing counsel and parties to litigation; and (ii) other third parties as may otherwise be permitted by law.

We may also share your personal information with our service providers such as our fund administrator (if applicable), IT providers, email providers, CRM provider, custodians, auditors, legal counsel, compliance consultants, web hosting providers, analytics providers, or other entities that have agreed to limitations on the use of your personal information, or entities that fit within other exemptions or exceptions in or as otherwise permitted by, the CCPA. List relevant types of service providers accurately. We also may disclose personal information about you or your accounts to a third party at your request or direction or with your consent.

California Residents’ Rights under the CCPA

If your personal information is subject to the CCPA, you may have certain rights concerning that information, subject to applicable exemptions and limitations, including the right to:

  • Know/Access: Request information about the categories and specific pieces of personal information we have collected about you, the categories of sources from which we collected it, the purposes for collecting it, and the categories of third parties to whom we disclose it.

  • Delete: Request that we delete personal information we have collected from you, subject to certain exceptions (e.g., information needed to complete a transaction, comply with legal obligations, or pursuant to the Gramm-Leach-Bliley Act).

  • Correct: Request that we correct inaccurate personal information that we maintain about you.

  • Not Be Discriminated Against: Be free from discriminatory treatment for exercising your CCPA rights.

  • Limit Use of Sensitive Personal Information: Request limitations on the use or disclosure of your sensitive personal information (if collected and used for purposes beyond those permitted by CCPA regulations.

  • Opt-Out of Sale/Sharing: Opt-out of the “sale” or “sharing” (for cross-context behavioral advertising) of your personal information. (As stated above, Celeres does not sell or share personal information as defined by the CCPA).

The CCPA does not restrict our ability to do certain things like comply with other laws or comply with regulatory investigations. In addition, the CCPA does not apply to certain information like personal information collected, processed, sold or disclosed pursuant to the federal Gramm-Leach-Bliley Act (GLBA) and its implementing regulations, which may cover much of the information related to investors in private funds. We also reserve the right to retain, and not to delete, certain personal information after receipt of a Request to Delete from you where permitted by the CCPA, GLBA, or another law or regulation.

How to Submit a Request under the CCPA

You may submit a Request to Know, Request to Delete, or Request to Correct, as described above, through the following methods:

  • Email: admin@celerescapital.com

  • We are required to provide certain information, delete personal information, or correct personal information only in response to verifiable requests made by you or your authorized agent. When you submit a request, we may ask that you provide clarifying or identifying information to verify your identity or authority to make the request. Such information may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, your name and email address, or other information necessary to verify your identity against the information we maintain. Any information gathered as part of the verification process will be used for verification purposes only. If you use an authorized agent to submit a request, we may require proof that the agent is authorized to act on your behalf.

Contact for More Information

If you have any questions or concerns about this California-specific Privacy Policy or Celeres' privacy practices, please contact us using the methods provided above:

  • Email: admin@celerescapital.com