Privacy Policy

Primary Commodity Fund is committed to protecting the privacy of our investors, partners, and website visitors. This Privacy Policy outlines how we collect, use, and safeguard your personal data in accordance with applicable laws, including the Bermuda Personal Information Protection Act (PIPA) and the European Union’s General Data Protection Regulation (GDPR), where applicable.

Data Collection

We may collect personal information that you provide directly to us through forms, emails, or other interactions, including:

  • Name, email address, phone number, and other contact details
  • Information provided for inquiries, subscriptions, or services
  • Technical data, such as IP addresses and browsing behavior, through cookies and analytics tools

Data Use

Your personal data will be used for the following purposes:

  • To provide and improve our products or services
  • To respond to inquiries or requests
  • To comply with legal and regulatory obligations
  • For marketing and promotional communications (with your consent)

Legal Basis for Processing

If you are located in the European Economic Area (EEA), we process your personal data based on the following legal grounds:

  • Your consent (e.g., for marketing purposes)
  • The necessity of processing for contract performance
  • Compliance with legal obligations
  • Legitimate business interests

Data Sharing

We do not sell or rent your personal data. However, we may share it with:

  • Trusted service providers for business operations (under strict confidentiality agreements)
  • Legal or regulatory authorities if required by law

Data Retention

Your personal data will be retained only for as long as necessary to fulfill the purposes outlined in this policy or comply with legal obligations.

International Data Transfers

As a company based in Bermuda, your data may be transferred and processed outside the EEA. We ensure appropriate safeguards are in place to protect your information in line with GDPR and PIPA requirements.

Your Rights

If you are located in the EEA, you have the following rights under the GDPR:

  • Right to access, correct, or delete your personal data
  • Right to object to or restrict processing
  • Right to data portability
  • Right to withdraw consent for processing (where applicable)
  • Right to lodge a complaint with your local data protection authority

If you are located in California, residents have the following rights under the California Consumer Privacy Act:

  • Right to Know: Request information about the categories and specific pieces of personal information we collect, use, disclose, and share
  • Right to Delete: Request deletion of personal information, subject to certain exceptions
  • Right to Correct: Request correction of inaccurate personal information
  • Right to Opt Out: Opt out of the sale or sharing of personal information (if applicable)
  • Right to Limit Use of Sensitive Personal Information: Limit how we use sensitive personal information (if applicable)
  • Right to Non-Discrimination: You will not be discriminated against for exercising your rights

Cookies & Tracking Technologies

We use cookies and similar technologies to enhance your experience and analyze website usage. You can manage your cookie preferences through your browser settings.

Contact Us

Primary Commodity includes the following companies:

  • Primary Commodity Master Fund Limited
  • Primary Commodity Fund Limited
  • Primary Commodity Fund Managers Limited
  • Primary Commodity Fund Onshore, LLC (Delaware)
  • Primary Commodity Investment Manager,LLC (Delaware)

If you have questions about this Privacy Policy or wish to exercise your data rights, please contact us at:

Primary Commodity Fund Managers Limited, 4th Floor, the Vallis Building, 58 Par-La-Ville Rd., Hamilton HM 11, Bermuda

Email: info@primarycommodity.com

Effective date: 31 March 2026

By using this website, you acknowledge that you have read and understood this Privacy Policy.