Global Privacy Notice of Millburn Ridgefield LLC and Affiliated Entities
Millburn Ridgefield LLC and its affiliates (“Millburn,” the “Company,” or “we,” “us,” or “our”) care about your privacy and recognize the importance of protecting your personal information. Furthermore, we are required by applicable law to make certain disclosures to you about our data privacy practices. Accordingly, below is our privacy notice (the “Notice”) describing the kind of personal information we may collect during your visit to our website (the “Site”) or through your other interactions with us.
For purposes of this Notice, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. It does not include de-identified or aggregate information, or public information lawfully available from governmental records. Depending on who you are and the nature of your interaction with Millburn, some of the Personal Information we collect may be nonpublic personal information. For purposes of this Notice, “affiliated entities” are companies related by common ownership or control, which may include financial and nonfinancial companies.
By accessing the Site, you agree to our collection and use of Personal Information as described in this Notice and in accordance with our Terms of Use.
This Notice applies to Millburn Ridgefield LLC, its affiliates, Millburn International (Europe) LLP, and to each investment vehicle sponsored by Millburn Ridgefield LLC and to which Millburn Ridgefield LLC serves as the general partner, investment manager, investment adviser, or in a similar capacity. Additional information applicable specifically to Millburn International (Europe) LLP is discussed below.
This notice was last updated March 2026.
Millburn Ridgefield LLC and Affiliated Entities Privacy Notice Summary
Financial institutions like Millburn are required to provide privacy notices to their clients and federal law also requires us to tell you how we collect, share, and protect your personal information. We believe that protecting the privacy of your Personal Information is of the utmost importance, and we are committed to maintaining the privacy of your Personal Information in our possession. As required by applicable rules, we are providing you with the following information. Please read this privacy notice carefully to understand what we do.
What Personal Information Does Millburn Collect and What Personal Information has Millburn Collected in the Past 12 Months?
We collect Personal Information about you, which may include nonpublic personal information, in the following ways:
(i) Information we receive from you on managed account agreements, fund subscription documents, and related forms (for example, name, address, Social Security number, birth date, bank or broker account information, assets, income, and investment experience);
(ii) Information collected during your transactions with us (for example, account activity and balances, and information regarding the account from which you make an investment or to which redemption or withdrawal proceeds are paid);
(iii) We may also collect Personal Information from you automatically, when you visit our Site. This information may include your IP address, your device and browser type, and information about your interaction with our Site and advertisements; and
(iv) We may also collect your Personal Information from publicly available sources.
The categories of Personal Information we may have collected from these sources during the 12 months preceding the date of this Notice, and will continue to collect, include the following:
(i) Personal identifiers: Name, contact information, address, email address, telephone numbers, Social Security number, username and password, and other similar information.
(ii) Financial information: Bank account and investment information.
(iii) Protected class information: Age and birth date.
(iv) Internet or other electronic activity information: Device and browser type, your browsing and search history on our Sites, and information regarding your interaction with our Sites and our advertisements.
(v) Inferences drawn from the Personal Information identified above.
What Does Millburn Do With Your Personal Information?
We use your Personal Information to provide our services to you – for example, to service your account and process your transactions. We may also use Personal Information to contact you from time to time to provide you with customer support, advertisements and marketing promotions, and offers about products or services we think may be of interest to you. Millburn does not disclose nonpublic personal information about our current and former clients and investors to third parties other than as described below. We do not sell nonpublic personal information about clients or investors to anyone, nor do we share your information with non-affiliated third parties for them to market to you. We also do not share information about your creditworthiness with our affiliates for their everyday business purposes or for them to market to you.
We may also use Personal Information about your use of our Site to monitor and improve our Site; for internal business analysis; to prevent fraud, activities that violate our Terms of Use or that are illegal; and to protect our rights and the rights and safety of our users or others.
How Do We Share and Have We Shared Your Personal Information for Business Purposes in the Past 12 Months?
Financial companies like Millburn choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. The following chart describes the categories of Personal Information that we disclosed to third parties for a business purpose in the 12 months prior to the date of this Notice:
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Categories of Consumers’ Personal Information |
Categories of Third Parties With Which We Shared Personal Information for a Business Purpose |
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Personal identifiers : Name, contact information, address, email address, telephone numbers, Social Security number, username and password, and other similar information. |
Service providers that service your account or the investment funds in which you invest, such as, account or fund administrators and vendors that conduct anti-money laundering, know-your-customer requirements, and background checks; provide customer relationship management (CRM) services; assist us in operating, analyzing, and displaying content on our website; provide analytics information; advertise or market our products; provide website hosting, webcast and teleconference services; provide legal and accounting services. |
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Financial information : Bank account and investment information. |
Service providers that service your account or the investment funds in which you invest, such as, account or fund administrators and vendors that conduct anti-money laundering, know-your-customer requirements, and background checks; provide legal and accounting services. |
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Protected class information : Age and birth date. |
Service providers that service your account or the investment funds in which you invest, such as, account or fund administrators and vendors that conduct anti-money laundering, know-your-customer requirements, and background checks; provide legal and accounting services. |
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Internet or other electronic activity information : Device and browser type, your browsing and search history on our Sites, and information regarding your interaction with our Sites and our advertisements. |
Service providers that service your account or the investment funds in which you invest, such as, account or fund administrators and vendors that conduct anti-money laundering, know-your-customer requirements, and background checks; provide customer relationship management (CRM) services; assist us in operating, analyzing, and displaying content on our website; provide analytics information; advertise or market our products; provide website hosting, webcast and teleconference services; provide legal and accounting services. |
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Inferences drawn from the Personal Information identified above . |
Service providers that service your account or the investment funds in which you invest, such as, account or fund administrators and vendors that conduct anti-money laundering, know-your-customer requirements, and background checks; provide customer relationship management (CRM) services; assist us in operating, analyzing, and displaying content on our website; provide analytics information; advertise or market our products; provide website hosting, webcast and teleconference services; provide legal and accounting services. |
or
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Categories of Personal Information |
Purposes of Processing |
Legal Bases |
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Contact Data; Financial Data; Onboarding Data |
To create, manage, and administer accounts you hold with the Company or with an investment product or fund, including assessing and processing applications and redemptions, communicating with you about your holdings and account related activities on an on-going basis |
This use of your Personal Information is necessary for performance of your contract with us (Article 6(1)(b), GDPR) |
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To manage and maintain our relationships with you, maintain records, and for ongoing customer service, including responding to Client requests |
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Contact Data; Financial Data; Onboarding Data |
To report tax-related information to tax authorities |
This use of your Personal Information is necessary in order for us to comply with our legal or regulatory obligations (Article 6(1)(c), GDPR) |
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To verify your identity and conduct identity and background checks for anti-money laundering purposes where you or your related organization are applying for Company products or services |
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To share data with police, law enforcement, tax authorities, or other government and fraud prevention agencies where we have a legal obligation, including screening transactions, reporting suspicious activity, and complying with production and court orders |
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To conduct investigations and comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations, and Company policies and terms |
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To monitor electronic communications for investigation and fraud prevention purposes, crime detection, prevention, and investigation |
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To perform accounting, auditing, billing and reconciliation activities, and other internal functions |
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To protect against, identify, and prevent fraud, copyright infringement, unauthorized use and distribution of protected content and other unlawful activity, claims, and liabilities |
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Contact Data; Financial Data; Onboarding Data |
The day-to-day running and management of the Company, including to: · monitor, maintain, and improve the processes, information and data, technology and communications solutions and services used by us · develop, manage, and improve Company business, products, and services, including performing data analyses (such as market and customer research) · determine and manage the effectiveness of Company communications · share such Personal Information with third parties that acquire or are interested in acquiring all or part of our assets or shares, or that succeed us in carrying on our business |
This use of your Personal Information data is necessary for our legitimate business interests in managing our business including for legal, personnel, administrative, and management purposes and for the prevention and detection of crime provided our interests are not overridden by your interests (Article 6(1)(f), GDPR) |
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Contact Data |
To send Clients promotional or advertising materials, and/or send information about the Company and its affiliates that may be of interest to Clients unless you advise us that you do not wish to receive marketing or market research communications from us. |
If applicable law requires that we receive your consent before we send you certain types of marketing communications, we will only send you those types of communications after receiving your consent. If you wish to stop receiving marketing or market research communications from us, you can unsubscribe via the link at the bottom of the relevant marketing email or contact us using the contact details below |
The Company also may use the Personal Information obtained in other ways for which the Company provides specific notice at the time of collection.
Please note that you have a right to object to the processing of your Personal Information where that processing is carried out for the Company’s legitimate interest or for direct marketing.
Where we require your Personal Information to comply with AML or other legal requirements, failure to provide this information means the Company may not be able to accept you as a Client and/or may not be able to process, or release your investments. This may result in the Company terminating its relationship with you.
Disclosure to Certain Third Parties
The Company does not sell or otherwise share Personal Information about you, except as described in this notice. The Company shares your Personal Information with its affiliates, including Millburn Ridgefield LLC, for the purposes identified in this notice. The Company also shares the information with service providers who perform services on its behalf based on its instructions and record your information in one or more databases maintained by third parties in connection with the collection of data and communications and for legal or regulatory purposes, as described in this notice. The Company does not authorize these service providers to use or disclose the information except as necessary to perform services on its behalf or comply with legal requirements. Examples of these service providers include fund administrators and entities that perform anti-money laundering testing services. In addition, the Company may share your Personal Information with your authorized representatives and other third parties to address anti-money laundering and know-your-customer requirements.
The Company also may disclose information about you (1) if the Company is required to do so by law or legal process (such as a court order or subpoena); (2) to law enforcement authorities or other government entities based on a lawful disclosure request; (3) to establish, exercise, or defend the Company’s legal rights; (4) when the Company believes disclosure is necessary or appropriate to prevent harm or financial loss; (5) in connection with an investigation of suspected or actual fraudulent or illegal activity; or (6) otherwise with your consent. The Company reserves the right to transfer Personal Information it has about you in the event of a potential or actual sale or transfer of all or a portion of the Company’s business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, spin-off, dissolution, or liquidation).
Transfer of Personal Information Outside the EEA/UK
The Company may disclose Client Personal Information to other recipients located in countries outside of the EEA or the UK, including affiliates located in the United States, which may not have data privacy laws equivalent to those in the EEA or the UK. Where we transfer Personal Information outside the EEA/UK, we will enter into a data transfer agreement with the recipient, seek assurances from the recipient that they have Binding Corporate Rules in place, or rely on a derogation such as, where the transfer is necessary for performance or a contract or the establishment or defense of legal claims). More details on the transfer mechanisms can be obtained using the contact details at the end of this Notice.
EU/ UK Data Subject Rights
Under applicable EU/UK data privacy laws, Clients may have a right to: (i) request access to and rectification or erasure of their Personal Information; (ii) obtain restriction of processing or object to processing of their Personal Information; and (iii) ask for a copy of their Personal Information to be provided to them, or to a third party, in a digital form. If you wish to exercise any of these rights you should contact investor.relations@millburn.com. Clients also have the right to lodge a complaint about the processing of their Personal Information with their local data protection authority.
Updates
This notice and the policies described in this notice may be updated periodically and without prior notice to you to reflect changes in Company’s privacy practices or in applicable law, rules, or regulations. The date as of which this notice was last updated appears at the beginning of the notice.
Contact Us
If there are any questions regarding this Notice or to request a copy of this Notice in another format you may contact us using the information below.
investor.relations@millburn.com
+1 855 802 8241
Millburn Ridgefield LLC
55 West 46th Street, 31st Floor
New York, NY 10036