Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it.

The provision of your personal data is voluntary. Please note that if you do not provide us with the required personal information, we may not be able to provide your requested information, products or services.

Who we are

For the purposes of applicable data protection laws, affiliates of Apis Capital Advisors, LLC (the “Fund”, “Master Fund” or “our affiliates”) and Apis Capital Advisors, LLC act as data controllers (collectively, the “Controller”, “we”, “us” or “our”).

Information covered by this Privacy Notice

This Privacy Notice covers all personal information collected and used by us. “Personal data” or “personal information” means information that (either in isolation or in combination with other information held by us) enables you to be identified as an individual or recognised directly or indirectly. This includes the types of information set out below.

We will only collect personal data for lawful and relevant purposes and we will take all practicable steps to ensure that personal data held by us is accurate. We will take all practicable steps to ensure security of the personal data and to avoid unauthorised or accidental access, erasure or other use.

What information do we collect from you and how do we use it?

We may collect personal information (such as your name, postal and email address, previous addresses, telephone and fax number, occupation, assets, income, nationality, marital status, passport or other identification details, employment details) that you provide to us when you submit a subscription application, and if and when you subsequently correspond with us.

From time to time, we may need to use your personal data for the following purposes:

We process your information in these ways where this is necessary for us to comply with legal requirements to which we are subject, perform our contractual obligations to you, or for the purposes of our own legitimate business interests in assessing your subscription application.

Sharing your data with third parties

Personal data will be kept confidential but, subject to the provisions of any applicable law, may be shared with any of the following persons for the above purposes:

Some of these parties may be located outside the European Economic Area (“EEA”), in which case we will take steps to bring such parties into compliance so that your personal information is treated securely and in accordance with this Privacy Notice and applicable data protection laws, including, where relevant, entering into EU standard contractual clauses (or equivalent measures) with the party outside the EEA receiving the personal information.

We use third party service providers, who are the data processors for purposes of data protection law, in order to administer and provide services to investors of the Fund and the Master Fund including maintaining the register of investors of the Fund and the Master Fund, receiving and processing subscription and redemption agreements or applications, submitting to investors a statement of their holdings in the Fund upon request, calculation of net asset value, maintenance of accounting reports, preparation of financial statements for audit purposes upon request and liaison with auditors.

Use of personal data for direct marketing purposes

  1. The Controller intends to use your name, contact details, products and services portfolio information, transaction pattern and behaviour, financial background and demographic data held by the Controller from time to time for direct marketing of the products/services offered by the Controller and/or our affiliates.
  2. The Controller intends to conduct direct marketing in relation to financial, investment and securities products and services that the Controller, our affiliates and our business partners may offer.
  3. The above products and services may be provided by the Controller and/or
    • any of our affiliates;
    • the business partners of the Controller and/or affiliates providing the products and services set out in 2.
  4. The Controller requires your written consent (which includes an indication of no objection) to use your personal data for any promotional or marketing purpose.

You may withdraw your consent to the use of your personal data for direct marketing purposes at any time, and thereafter the Controller shall, without charge to you, cease to use such data for direct marketing purposes. If you wish to withdraw your consent, please contact

Where we store your personal information

The personal information that we collect from you may be transferred to, and stored at, a destination outside the EEA. It may also be processed by staff operating outside the EEA who work for us or for one of the third party organisations with whom we share personal information (see the section “Sharing your data with third parties” above).

We will take measures reasonably necessary to bring third parties into compliance in accordance with this Privacy Notice and applicable data protection laws, including, where relevant, entering into EU standard contractual clauses (or equivalent safeguards) with the party outside the EEA receiving the personal information.

Your rights

You have the right to:

Requests for access and correction or for any other information regarding our data protection policies and practices and types of data held should be addressed in writing to:

A reasonable fee may be charged to offset the Controller’s administrative and actual costs incurred in complying with your access requests.

You also have the right to lodge a complaint with the local data protection authority if you believe that we have not complied with applicable data protection laws. If you are based in, or the issue relates to, the UK, the Information Commissioner’s Office can be contacted as follows:

If you are based or the issue you would like to complain about took place elsewhere in the EEA, please go to for a list of local data protection authorities in the other EEA countries.

How long do we keep your personal information?

We will only retain your personal data for as long as it is necessary for the purpose for which that data was collected and to the extent permitted by applicable laws. When we no longer need to use your information, we will remove it from our systems and records and/or take steps to properly anonymise it so that you can no longer be identified from it (unless we need to keep your information to comply with legal or regulatory obligations to which we are subject).

How do we keep your personal information secure?

We have implemented technical and organisational security measures in an effort to safeguard the personal information in our custody and control. Such measures we have implemented include, for example, limiting access to personal information only to employees and authorised service providers who need to know such information for the purposes described in this Privacy Notice as well as other administrative, technical and physical safeguards.

While we endeavour to always protect our systems, sites, operations and information against unauthorised access, use, modification and disclosure, due to the inherent nature of the Internet as an open global communications vehicle and other risk factors, we cannot guarantee that any information, during transmission or while stored on our systems, will be absolutely safe from intrusion by others, such as hackers.

How to contact Us

If there are any questions or concerns regarding this Privacy Notice or the data collection practices outlined herein, please contact

Changes to this Privacy Notice

This Privacy Notice is written in English and may be translated into other languages. In the event of any inconsistency between the English version and the translated version of this notice, the English version shall prevail.

We reserve the right to change this Privacy Notice from time to time. If we decide to change this Privacy Notice we will notify you of these changes via email and/or take any other action as required by applicable law and/or take any other action as required by applicable law.

Declaration and authorisation: I/We acknowledge and confirm that I/we have read and understood the Privacy Notice. I/we hereby give my/our acknowledgement and agree to the use and transfer of my/our personal data by the Controller in accordance with the Privacy Notice, including the use of my/our personal data for the purpose of direct marketing. I/we acknowledge and consent to cross-border transfer of my/our personal data for the purposes and to the types of transferee as set out in the Privacy Notice.

Important: If you do not agree to the use of your personal data for direct marketing as set out in the section “Use of personal data for direct marketing purposes”, and no longer wish to receive our communications, you can opt out at any time by emailing and indicate your preference to “unsubscribe.”