PALOMA is a
multi-strategy investment adviser that has operated across decades
and many market cycles. We seek to generate attractive, long term, risk
adjusted returns with low correlation to markets.
IMPORTANT DISCLOSURES & AGREEMENTS
Since our founding we have built a reputation for
longevity in hedge fund investing. We pursue attractive risk/reward
opportunities in all strategies, but we have traditionally focused on
quantitative and relative value approaches.
Donald Sussman
Founder, Chairman and Chief Investment Officer
Donald Sussman is the Founder and Chairman of
Paloma Partners Management Company and Chief Investment Officer of its
flagship fund. Mr. Sussman was named to the Institutional
Investor-Alpha Hedge Fund Hall of Fame in 2013. He was the
recipient of Hedge Funds Review’s Lifetime Achievement Award in 2013 and
Institutional Investor’s Alternative Investment News Lifetime
Achievement Award in 2004. Mr. Sussman is an Honorary Trustee and
former Co-Chair of the Investment Committee of Carnegie Hall. He
is a Trustee/Board member of Emily’s List, Center for American
Progress, as well as an Honorary Trustee of the Ethical Culture
Fieldston School. Mr. Sussman received the Horatio Alger Award in
2023 for professional achievement and philanthropy. Mr. Sussman
attended Columbia College and received a B.S. and an MBA from New York
University as well as an Honorary Doctorate from the Weizmann Institute
of Science and Maine College of Art.
Ravi M. Singh
Chief Executive Officer
Ravi M. Singh is the Chief Executive Officer of
Paloma Partners Management Company. Mr. Singh joined PPMC in February
2024. Previously, he was a Managing Director and Head of Strategic
Initiatives at ORIX Corporation USA from 2020 through 2023. Over his
time at Orix, Mr. Singh oversaw Lument (Orix’s commercial real estate
agency platform), ran the Special Opportunities Group leading the
origination, underwriting and oversight of portfolios in opportunistic
credit and financing transactions and also managed ORIX’s Private Equity
Solutions and Latin American businesses. He was a member of OCU’s
Management Committee. Prior to Orix, Mr. Singh was a Managing Director
and Head of Alternative Investments globally in the Asset Management
Division of Credit Suisse from 2009 until 2012. In that capacity, he
managed teams responsible for over $160bn of CS’ Hedge Fund, Private
Equity and Fund-of-Funds businesses. Mr. Singh joined Credit Suisse from
Goldman Sachs, where he was co-head of their Prime Brokerage business
for six years. He retired from Goldman in November 2008 after 19 years,
the last eight years serving as a Partner. Over the course of his career
at Goldman, prior to running Prime Brokerage, Mr. Singh managed various
Equity Derivative trading businesses in New York and in London. Mr.
Singh graduated from Columbia University in 1989 with a BA in
Economics.
We seek to invest and manage based on certain core principles.
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Dynamic Allocation
DYNAMIC CAPITAL ALLOCATION among a changing group of strategies and portfolio managers as market opportunities shift
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Flexible Trading Model
FLEXIBLE TRADING MODEL designed for the realities of ever changing markets
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Risk Management
A focus on RISK MANAGEMENT and capital preservation
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INVESTMENT TALENT
The ongoing search for accomplished and innovative INVESTMENT TALENT
Talent is the lifeblood of our business. Paloma's ability to
partner with seasoned investment teams in a variety of ways makes us
unique. We are always eager to speak with accomplished and innovative
investment professionals who exhibit a strong respect for capital and
risk management.
Interested candidates can review our open mandates and submit general
inquiries via the recruiting portal. We look forward to hearing from
you!
Apply Now
IMPORTANT DISCLOSURES
The information on this website does not constitute investment
advice. In addition, the information on this page does not convey an
offer of any type and is not intended to be, and should not be construed
as, an offer to sell, or the solicitation of an offer to buy, any
securities or other financial products. No assurances can be made that
any intentions, assumptions, expectations, strategies, and/or goals
expressed or implied herein were or will be realized or that the
activities or any performance described did or will continue at all or
in the same manner as is described on this website.
As part of its registration with the U.S. Securities and Exchange
Commission Paloma Partners has filed a Form ADV. This filing contains
information about Paloma. You may access Paloma’s Form ADV at Investment Adviser Public Disclosure.
Contact Us
Contact us:
Two American Lane
Greenwich, CT 06836
Telephone: 203.861.3236
Email: info@paloma.com
To contact our administrator, SS&C Financial Fund Services, please use the following contact information:
Facsimile: (860) 371-2503
E-mail: Paloma.IR@sscinc.com
For any trade related correspondence, please use: ISTradeDesk@sscinc.com
Privacy Notice
Your privacy is very important to us. This notice (this
"Privacy Notice") is provided by Paloma Partners Management Company
("PPMC"), Paloma Partners Advisors LP ("PPA"), and the Paloma Fund , and
corresponding parallel, alternative and other fund vehicles managed and
administered by PPMC or PPA (the "Fund" and together with PPMC and PPA,
"us" or "we") and sets forth the policies of the Fund for the
collection, use, storage, sharing, disclosure (collectively,
"processing") and protection of personal data relating to current,
prospective and former investors in the Fund. This Privacy Notice
is being provided in accordance with the requirements of data privacy
laws, including, the Cayman Islands Data Protection Act (As Revised)
("DPA") or any other law relating to privacy or the processing of
personal data and any statutory instrument, order, rule or regulation
implemented thereunder, each as applicable to the Fund (collectively,
"Data Protection Laws"). References to "you" or an "investor" in
this Privacy Notice mean any investor who is an individual, or any
individual connected with an investor who is a legal person (each such
individual, a "data subject"), as applicable.
Capitalized terms used herein but not defined herein shall have the
meanings assigned to them in the applicable Confidential Private
Offering Memorandum of the Fund as may be supplemented, updated or
modified from time to time (the "Memorandum").
Types of information we collect and the purposes for which it is processed:
Account Registration and Management: We collect names, residential
addresses and other contact details (phone, fax, email), signature, and
we may collect some or all of the following: nationality, passport
number, tax identification number, date of birth, place of birth, photo
ID, copies of government issued identification documents, bank account
details, account balances and transaction information, information about
assets or net worth, credit history, or source of funds details. We
collect this information to fulfill our contract to provide our investor
services and to comply with legal and regulatory obligations. We
have a legitimate interest in providing account related functionalities
to our investors. We have a legitimate interest in managing and
administering services to our current, prospective, and former
investors.
Demographic Information: We may collect information such as your age or
location. We have a legitimate interest in understanding our investors.
We also may need to collect this information to comply with legal
and regulatory obligations.
Web logs and First Party Cookies: We collect information from you,
including your browser type, operating system, Internet Protocol (IP)
address (a number that is automatically assigned to your computer when
you use the internet), domain name, click-activity, referring website,
and/or a date/time stamp for your visit. We have a legitimate interest
in monitoring and operating our networks and website.
Business partner contacts: We collect the name and contact information
of employees of third parties with whom we may interact, including
vendors. We have a legitimate interest in contacting and communicating
with third parties about business activities.
How we collect personal data
We may collect personal data about you through: (i) information provided
directly to us by you, or another person on your behalf when you submit
a subscription document to invest in the Fund; (ii) information that we
obtain in relation to any transactions between you and us; and (iii)
electronic communications with you. We also may receive your
personal information from third parties or other sources, such as our
affiliates identified at the top of this Privacy Notice, the
Administrator, marketing or business development partners, publicly
accessible databases or registers, tax authorities, governmental
agencies and supervisory authorities, credit agencies, fraud prevention
and detection agencies, or other publicly accessible sources, such as
the Internet. Where personal data is required to satisfy a
statutory obligation (including compliance with applicable anti-money
laundering or sanctions requirements) or a contractual requirement,
failure to provide such information may result in your subscription in
the Fund being rejected or compulsorily redeemed. Where there is
suspicion of unlawful activity, failure to provide personal data may
result in the submission of a report to the relevant law enforcement
agency or supervisory authority.
How we share your personal data
All financial companies need to share customers’ personal data to run
their everyday business. Below, we list the ways we share personal
data collected in accordance with applicable Data Protection Laws and
whether you can limit such sharing. To request that we limit
sharing where permitted, please contact us using the information below.
We may share your personal data:
• For our everyday business purposes (such as to
process your transactions, maintain your account(s), respond to court
orders and legal investigations, or report to credit bureaus). You
cannot limit this sharing.
• For our marketing purposes (to offer our products
and services to you). You can sometimes limit this sharing.
• For our affiliates’ everyday business purposes (such
as information about your transactions and experiences). You
cannot limit this sharing.
• With our affiliates for direct marketing purposes,
such as offers of products and services to you by our affiliates.
You have the right to limit this type of sharing. If you are
a new investor, under U.S. federal law, we can begin sharing your
personal data with our affiliates for their own (if any) direct
marketing purposes 30 days from the date we sent this Privacy Notice.
When you are no longer our investor, we may continue to share your
personal data with our affiliates for such purposes. We may also
disclose information about your transactions and experiences with us to
our affiliates for their everyday business purposes.
We do not share your personal data with non-affiliates except as
required or permitted by law. We do not share your personal data
with non-affiliates for them to market to you, and we do not share your
personal data for joint marketing with other financial companies.
If you limit sharing for an account you hold jointly with someone
else, your choices will apply to everyone on your account. U.S.
state laws and applicable foreign jurisdictions may give you additional
rights to limit sharing.
In addition to the specific situations discussed above, we disclose personal data in the following situations:
1. Affiliates and Acquisitions. We may share
personal data with our corporate affiliates (e.g., parent company,
sister companies, subsidiaries, joint ventures, or other companies under
common control). If another company acquires, or plans to
acquire, our company, business, or our assets, we will also share
personal data with that company, including at the negotiation stage.
2. Other Disclosures with Your Consent. We may
ask if you would like us to share your personal data with other
unaffiliated third parties who are not described elsewhere in this
notice.
3. Other Disclosures without Your Consent. We
may disclose personal data in response to subpoenas, warrants, or court
orders, or to relevant regulatory authorities, or to tax authorities or
in connection with any legal process, or to comply with relevant laws.
We may also share your personal data to establish or exercise our
rights, to defend against a legal claim, to investigate, prevent, or
take action regarding possible illegal activities, suspected fraud,
safety of person or property, or a violation of our policies, or to
comply with your request for the provision of services by a third-party
intermediary. It may also be necessary, under anti-money
laundering and similar laws, to disclose personal data about the Fund’s
investors to accept subscriptions from them or to facilitate the
establishment of trading relationships for the Fund with executing
brokers or other trading counterparties. We will also release
personal about you if you direct us to do so.
4. Service Providers. We share your personal
data with service providers. Among other things, service providers
help us to administer our fund, provide technical support, administer
our website, send you mailings and other information, and process
subscriptions and redemptions. Service providers also include, but
not are not limited to, our Administrator, Prime Brokers, website
service providers, marketing and customer relationship service
providers, Custodians, Auditors, Legal Advisers and executing brokers
and trading counterparties.
Monitoring of communications
We may monitor electronic communications with you for the purposes of:
(i) ascertaining the details of instructions given, the terms on which
any transaction was executed or any other relevant circumstances; (ii)
ensuring compliance with our regulatory obligations; and/or (iii)
detecting and preventing the commission of financial crime.
Retention periods and security measures
We will not retain personal data for longer than is necessary in
relation to the purpose for which it is collected, subject to applicable
Data Protection Laws. Personal data will be retained for the
duration of your investment in the Fund, and for a period of ten years
after a redemption of an investment from the Fund, or liquidation of the
Fund. We may retain personal data for a longer period for
internal compliance purposes or compliance with applicable law.
From time to time, we will review the purpose for which personal
data has been collected and decide whether to retain it or to delete if
it no longer serves any purpose to us.
No method of transmission of the internet or method of electronic
storage is fully secure. While we use reasonable efforts to
protect your personal data from unauthorized access, use, or disclosure,
we cannot guarantee the security of your personal data. These
measures include computer safeguards and secured files and buildings.
If we are required by applicable law to inform you of a breach to
your personal data, we may notify you electronically, in writing, or by
telephone, if permitted to do so by law.
International transfers
Because of the international nature of the fund management business,
personal data may be transferred to countries outside your country of
residence, including the European Economic Area (“EEA”), Switzerland, or
the Cayman Islands ("Third Countries"), such as to jurisdictions where
we conduct business or have a service provider. This may include
countries that may not have the same level of data protection as that
afforded by the applicable Data Protection Laws in your country of
residence, including, but not necessarily limited to, the United States.
In such cases, we will process personal data (or procure that it
be processed) in the Third Countries in accordance with the requirements
of applicable Data Protection Laws, including through Standard
Contractual Clauses used for the transfer of personal data outside of
the EEA, Switzerland, or the Cayman Islands.
Automated decision-making
We will not take decisions producing legal effects concerning you, or
otherwise significantly affecting you, based solely on automated
processing of your personal data, unless we have considered the proposed
processing in a particular case and concluded in writing that it meets
the applicable Data Protection Law requirements.
Your Choices
Where required by law, investors in some jurisdictions can make the
following choices regarding their personal data, which you can do by
contacting us at the address, phone number, or email at the end of this
Privacy Notice:
1. Access to Your Personal Information. You may
request access to your personal data or confirmation that we are
processing your personal data. If required by law, upon request,
we will grant you reasonable access to the personal data that we have
about you.
2. Changes to Your Personal Information. We rely
on you to update and correct your personal data. If our website
does not permit you to update or correct certain information, you can
request that your personal data be modified. Note that we may keep
historical information in our backup files as permitted by law.
3. Deletion of Your Personal Information. You
may request that we delete your personal data. If required by law,
we will grant a request to delete your personal data, but you should
note that in many situations we must keep your personal data to comply
with our legal obligations, resolve disputes, enforce our agreements, or
for another one of our business purposes.
4. Objection to or Restriction of Certain Processing.
In certain circumstances, you may object to our processing of your
personal data, or request that we restrict processing of your personal
data. We will no longer process your personal data unless we have
compelling legitimate grounds for the processing which override the
interests, rights and freedoms of the data subject, or for the
establishment, exercise or defense of legal claims. Note that you
can object to processing for direct marketing purposes.
5. Revocation of Consent. Where we process your
personal data based on consent, if you revoke or restrict your consent,
we may no longer be able to provide you services.
6. Right to compensation for damage and to make a
complaint. Under the DPA, you have the right to be informed of a
personal data breach (unless the breach is unlikely to be prejudicial to
you) and may have a right to compensation for any damage that occurred
because of a personal data breach. Where you feel that your rights
are not being respected, you may submit a complaint to the Office of
the Ombudsman of the Cayman Islands or your appropriate supervisory
authority.
Please note, not all of the rights described above are absolute, and
they do not apply in all circumstances. In some cases, we may
limit or deny your request because the law permits or requires us to do
so, or if we are unable to adequately verify your identity. We do
not discriminate against any individuals who exercise their privacy
rights under applicable Data Protection Law.
Miscellaneous
• Changes to this Privacy Notice. We may change
our Privacy Notice and practices over time. New notices will be
published on our website. To the extent that our Privacy Notice
changes in a material way, the notice that was in place at the time that
you submitted personal data to us will generally govern that
information unless we receive your consent to the new privacy notice.
Our Privacy Notice includes an “effective” and “last updated”
date. The effective date refers to the date that the current
version took effect. The last updated date refers to the date that
the current version was last substantively modified.
• Additional Information for residents of
California. California law requires us to provide additional
information and rights pursuant to California law. You can find
additional information below.
• If you are not satisfied with our response and
are in the European Union or United Kingdom, you may have a right to
lodge a complaint with your local supervisory authority.
Who to contact about this Privacy Notice
Please contact Investor Relations at +1(203) 861-3236 or by writing to
the following address: Paloma Partners Management Company, Two American
Lane, Greenwich, Connecticut 06836-2571, United States of America or
info@paloma.com for any questions about this Privacy Notice or requests
with regards to the personal data we hold. For more specific
information or requests in relation to the processing of personal data
by the Administrator, Prime Brokers, Custodians or any other service
provider of the Fund, you may also contact the relevant service provider
directly at the address specified in the Directory section of the
Memorandum or by visiting their websites.
Effective date: April 2025
Last updated: April 2025
Additional Information for residents of California
If you are a California resident, the following privacy disclosures apply to you in addition to the rest of the Privacy Notice.
Categories of Information We Collect, Use and Disclose
California law indicates that organizations should disclose whether
certain categories of personal data are collected, “sold” or transferred
for “valuable consideration,” “shared” for purposes of cross-context
behavioral advertising, or transferred for an organization’s “business
purpose” (as those terms are defined under California law). We do
not “sell” your personal data or “share” your personal data for the
purposes of cross-context behavioral advertising. The table below
indicates the categories of personal information we collect and transfer
in a variety of contexts. Please note that because this list is
comprehensive, it may refer to types of information that we collect and
share about people other than you.
Categories of Personal Data We Collect To Whom We Disclose Personal Data for a Business Purpose
Identifiers – this may include real name, alias, postal address, unique
personal identifier, online identifier, email address, account name,
social security number, driver’s license number, passport number or
other similar identifiers.
• Affiliates or subsidiaries
• Business partners
• Government entities, as may be needed to comply with law or prevent illegal activity
• Internet service providers
• Operating systems and platforms
• Other Service Providers
• Professional services organizations, this may include auditors and law firms
Additional categories of personal information described in the
California Customer Records statute (Cal. Civ. Code § 1798.80(e)) – this
may include signature, physical characteristics or description, state
identification card number, insurance policy number, education, bank
account number, credit card number, debit card number, and other
financial information, medical information, and health insurance
information. • Affiliates or
subsidiaries
• Business partners
• Government entities, as may be needed to comply with law or prevent illegal activity
• Operating systems and platforms
• Other Service Providers
• Professional services organizations, this may include auditors and law firms
Characteristics of protected classifications – this may include age,
sex, race, ethnicity, physical or mental handicap, etc.
• Affiliates or subsidiaries
• Business partners
• Government entities, as may be needed to comply with law or prevent illegal activity
• Other Service Providers
• Professional services organizations, this may include auditors and law firms
Commercial information – this may include information about products or
services purchased, obtained, or considered, or other purchasing or
consuming histories or tendencies. N/A
Biometric information N/A
Internet or other electronic network activity information – this may
include browsing history, search history, and information regarding an
individual’s interaction with an internet website, application, or
advertisement. • Affiliates or
subsidiaries
• Business partners
• Government entities, as may be needed to comply with law or prevent illegal activity
• Internet service providers
• Operating systems and platforms
• Other Service Providers
Geolocation data N/A
Audio, electronic, visual, thermal, olfactory, or similar
information • Affiliates or
subsidiaries
• Government entities, as may be needed to comply with law or prevent illegal activity
• Other Service Providers
Professional or employment-related information • Affiliates or subsidiaries
• Government entities, as may be needed to comply with law or prevent illegal activity
• Operating systems and platforms
• Other Service Providers
• Professional services organizations, this may include auditors and law firms
Non-public education information (as defined in the Family Educational Rights and Privacy Act) N/A
Inferences drawn from any of the information listed above N/A
Sensitive Information Disclosure
We collect the following categories of sensitive personal information
(as defined under California law): (1) Social Security number, driver’s
license, state identification card, or passport number; and (2) contents
of a consumer’s mail or email where we are not the intended recipient.
This information is collected in order to process transactions,
comply with laws, manage our business, or provide you with services.
Note that we do not use such information for any purposes that are
not identified within the California Privacy Rights Act Section
1798.121. We do not “sell” or “share” sensitive personal
information for purposes of cross-context behavioral advertising.
California Shine the Light
If you would like more information concerning the categories of personal
data (if any) we share with third parties or affiliates for those
parties to use for direct marketing purposes, please submit a written
request using the contact information in the “Who to contact about this
Privacy Notice” section above.
Your Privacy Rights
California law provides California consumers with the right to request
(1) access to their personal data; (2) deletion of their personal data,
and (3) correction of their personal data, subject to certain
exceptions. These rights do not apply to personal data collected
pursuant to certain U.S. federal laws. As required by law, we may
need to request specific information from you to help us confirm your
identity. We may verify your identity by phone call or email and
we will ask for information such as your name, or other account
information. We may also ask you to provide a signed declaration
confirming your identity. California law permits you to designate
an authorized agent to submit requests to exercise certain privacy
rights on your behalf. We will require verification that you
provided the authorized agent permission to make a request on your
behalf. You must provide us with a copy of the signed permission
you have given to the authorized agent to submit the request on your
behalf and verify your own identity directly with us. If you are
an authorized agent submitting a request on behalf of an individual, you
must attach a copy of the following information to the request:
1. A completed Authorized Agent Designation Form
indicating that you have authorization to act on the consumer’s behalf.
2. If you are a business, proof that you are
registered with the Secretary of State to conduct business in
California.
If we do not receive both pieces of information, the request will be denied.
Do Not Track Disclosure
We do not currently recognize automated browser signals regarding
tracking mechanisms, which may include "Do Not Track"
instructions.
Accessibility
This Privacy Notice is accessible through your browser’s audio reader.
If you need to access this Privacy Notice in an alternative format
due to having a disability, please contact us using the contact
information in the “Who to contact about this Privacy Notice” section
above.
Paloma Partners Management Company (“PPMC”) Terms of Use:
By accessing or using this Paloma Partners Management Company
("PPMC") internet website (the "Site") you hereby accept and agree to
comply with the terms and conditions set forth in this User Agreement
(this "User Agreement"), and you shall be considered a "User." This User
Agreement is entered into by and between you and PPMC, and governs your
access to and use of the Site and the information ("Content") available
on the Site.
BY CLICKING "I AGREE" AT THE END OF THIS USER AGREEMENT, YOU ARE
AGREEING THAT YOU HAVE READ, UNDERSTAND AND ACCEPT THE TERMS AND
CONDITIONS CONTAINED HEREIN, WILL ABIDE BY THIS USER AGREEMENT IN ITS
THEN CURRENT FORM AND ARE LEGALLY BOUND BY THIS USER AGREEMENT.
General Provisions. PPMC hereby grants you a revocable,
nontransferable, nonexclusive right to use the Site solely in accordance
with this User Agreement. The foregoing license has been granted to you
subject to your agreement to abide by this User Agreement as well as
any other rules, procedures, policies, terms or conditions governing the
Site that may be displayed from time to time on the Site and to which
Users will be bound.
Passwords and Security. You may not access any password-protected
portion of the Site unless you received a password from and are
authorized by PPMC. You are solely responsible for any use of or action
taken under your password on the Site. You are solely responsible for
maintaining the confidentiality and security of your password, and you
hereby agree not to disclose your password to any third party. You
accept full responsibility for all activity conducted using your
password and
agree to and hereby release PPMC from any and all liability
concerning such activity. You agree to notify PPMC immediately of any
actual or suspected loss, theft or unauthorized use of your password.
PPMC has no obligation to inquire as to the authority or propriety of
any use of or action taken under your password and will not be
responsible for any loss to you arising from any such use or action or
from your failure to comply with the above.
Investigation and Disclosure of Information. PPMC has the right, but
not the obligation, to monitor any activity and Content associated with
the Site. PPMC may investigate any complaint or reported violation of
its policies and take any action that it deems appropriate. Such action
may include, but is not limited to, issuing warnings, suspending or
terminating your use of all or any portion of the Site and denying you
access to all or any portion of the Site. PPMC also reserves the right
to report any activity that it suspects may violate any law or
regulation to appropriate law enforcement officials, regulators, or
other persons or entities. In order to cooperate with governmental
requests, to protect PPMC's systems and Users, to ensure the integrity
and operation of PPMC's Site, business or systems, or otherwise to
comply with the law and legal process, PPMC may access and disclose any
information it considers necessary or appropriate.
Ownership. The Site, Content and any and all intellectual property
rights pertaining thereto (including but not limited to copyrights,
patents, trademarks and service marks) are owned and protected by PPMC
or third parties, and all right, title and interest therein and thereto
shall remain the property of PPMC and/or such third parties.
You agree that you will not publish, broadcast, retransmit, reproduce,
commercially exploit, create any derivative of or otherwise disseminate
any portion of the Site. Without limiting the foregoing or expanding any
of your rights hereunder, you may not use the Site to transmit,
distribute or store material (a) in violation of any applicable law or
regulation, (b) in a manner that will infringe the copyright, trademark,
trade secret or other intellectual property right of another or violate
the privacy, publicity or other personal right of another, or (c) that
is defamatory, obscene, threatening, abusive or hateful. You are
prohibited from violating or attempting to violate the security of the
Site. You may print copies of any accessible portion of the Site only
for your own personal use. You may discuss information that you learn
from the Site with your financial, legal or tax advisors, and others
with whom you share investment decisions.
You agree not to remove any copyright, trademark or other proprietary
notice or legend contained on the Site or its Content (or printed
copies thereof). PPMC, Paloma.com and other names and indicia of source
of PPMC and its services and funds it services, are exclusive trademarks
and service marks of PPMC, the funds it services, their advisors and
affiliates. Other product and company names and trademarks appearing on
the Site may be trademarks of their respective owners.
Termination. PPMC reserves the right to suspend or terminate your
access to and use of all or any portion of the Site at any time and for
any reason, in its sole discretion. This User Agreement will continue to
apply to your past use of the Site in the form in which it then existed
at the time of the subject use. Termination of your access to and use
of the Site does not relieve you of any obligations arising or accruing
prior to such termination or limit any liability that you otherwise may
have to PPMC.
No Advice, Offers or Solicitations. You acknowledge that the
information contained on the Site is not and should not be construed as
legal, regulatory, tax, accounting or investment advice (including any
advice concerning the suitability or profitability of any security,
investment or investment strategy). You acknowledge that the information
contained on the Site is not and should not be construed as an offer or
solicitation of any kind to buy or sell any securities or other
financial instruments. USERS SHOULD CONSULT WITH, AND SEEK PROFESSIONAL
ADVICE FROM, THEIR OWN ATTORNEYS, ACCOUNTANTS, TAX ADVISORS AND
FINANCIAL ADVISORS WITH RESPECT TO THEIR INDIVIDUAL CIRCUMSTANCES AND
NEEDS.
No Recommendations of Individual Securities or Strategies. You
acknowledge that the information contained on the Site is not and should
not be construed as advice or recommendations regarding individual
securities or investment strategies including advice or recommendations
concerning the suitability of individual securities or , investment
strategies. Research, analysis, news and other information made
available electronically do not constitute individualized
recommendations to buy, sell or otherwise invest in a particular
security or investment strategy
Past Performance. Past performance does not predict or guarantee
future return, and nothing on this Site should be interpreted to state
or imply otherwise.
Risks in relying on the Content. We make reasonable efforts to
provide accurate Content on the Site, but at times we may not promptly
update or correct the Site even if we are aware that it is inaccurate,
outdated or otherwise inappropriate. We may change all or any portion of
the Site at any time without notice to you. We do not endorse the
opinions of, or warrant the accuracy of facts or other Content
contributed by, any third party. You agree that we are not liable for
any action you take or decision you make in reliance on any Content.
Dated Content speaks only as of the date indicated. Opinions included on
the Site are subject to change at any time without notice.
No Liability for Technological Problems. All or any portion of the
Site may not be available and may not function properly at any time. We
make reasonable efforts to avoid technological problems, but at any time
the Site may have and may cause technological problems such as viruses
and other damaging computer programming routines or engines. We take
reasonable security precautions when using the Internet, telephone or
other means to transport data or other communications, but we disclaim
liability for any interception of data or communications. We make
reasonable efforts to ensure that the Site is secure but we do not
guarantee the security of the Site. We are not liable for any (a)
technological problems and any impact that they may have; (b) damage or
injury caused by the performance or failure of performance of all or any
portion of the Site; or (c) defects, delays or errors in or resulting
from your use of the Site.
Disclaimer of Warranties. THE SITE AND ALL INFORMATION AVAILABLE ON
OR VIA THE SITE ARE PROVIDED "AS IS" AND "AS AVAILABLE," WITHOUT
WARRANTY OF ANY KIND, EITHER EXPRESS OR IMPLIED, INCLUDING WITHOUT
LIMITATION: (1) ANY WARRANTIES CONCERNING THE AVAILABILITY, RELIABILITY,
ACCURACY, COMPLETENESS, TIMELINESS OR SEQUENCING OF THE SITE OR THE
CONTENT, PRODUCTS OR SERVICES AVAILABLE ON OR VIA THE SITE; AND (2) ANY
WARRANTIES OF TITLE OR EXPRESS OR IMPLIED WARRANTIES OF MERCHANTABILITY,
FITNESS FOR A PARTICULAR PURPOSE, OR NON-INFRINGEMENT OF INTELLECTUAL
PROPERTY AND PROPRIETARY RIGHTS. WITHOUT LIMITING THE FOREGOING, THIS
DISCLAIMER OF LIABILITY APPLIES TO ANY DAMAGES OR INJURY CAUSED BY ANY
FAILURE OF PERFORMANCE, ERROR, OMISSION, INTERRUPTION, DELETION, DEFECT,
DELAY IN OPERATION OR TRANSMISSION, COMPUTER VIRUS, COMMUNICATION LINE
FAILURE, THEFT, DESTRUCTION OR UNAUTHORIZED ACCESS TO, ALTERATION OF, OR
USE OF ANY ASSET, WHETHER FOR BREACH OF CONTRACT, TORTIOUS BEHAVIOR,
NEGLIGENCE OR UNDER ANY OTHER CAUSE OF ACTION.
Limitation of Liability. IN NO EVENT SHALL PPMC OR ANY OF ITS
AFFILIATES BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, PUNITIVE OR
CONSEQUENTIAL DAMAGES (INCLUDING, WITHOUT LIMITATION, DAMAGES FOR LOSS
OF DATA, BUSINESS OR PROFITS) ARISING OUT OF OR IN CONNECTION WITH THIS
USER AGREEMENT, WHETHER BASED ON CONTRACT, TORT, STRICT LIABILITY OR
OTHERWISE, EVEN IF PPMC OR ANY OF ITS AFFILIATES HAS BEEN ADVISED OF THE
POSSIBILITY OF SUCH DAMAGES, AND NOTWITHSTANDING THE FAILURE OF THE
ESSENTIAL PURPOSE OF ANY REMEDY. IN NO EVENT SHALL THE LIABILITY OF PPMC
OR OF ANY PPMC AFFILIATE IN ANY CIRCUMSTANCE EXCEED $100. WITHOUT
LIMITING THE FOREGOING PROVISIONS OF THIS PARAGRAPH, THESE LIMITATIONS
ALSO APPLY TO ANY THIRD PARTY CLAIMS AGAINST USERS.
Indemnity. You agree to indemnify, defend and hold harmless PPMC and
its affiliates from and against any and all suits, losses, claims,
demands, liabilities, damages, costs and expenses (including reasonable
attorneys' fees) arising from or relating to (a) your use of the Site;
(b) your breach of this User Agreement or any representation, warranty
or covenant made by you herein; or (c) your violation of any applicable
law, statute, ordinance, regulation or any third party's rights. This
obligation survives the termination of this User Agreement.
Modifications. PPMC may modify the terms of this User Agreement or
any of the policies or guidelines governing the Site, at any time and in
its sole discretion, by posting the modified User Agreement on the
Site. The modifications shall be effective upon such posting (unless
some other date is specified in the posting, in which case that date
shall be deemed the effective date for the modifications). You agree to
review this User Agreement periodically so that you are aware of any
modifications. Your use of the Site indicates your full acceptance of
the User Agreement in its then-current form each time you use the Site.
You agree that the notice provisions provided in this User Agreement are
reasonable. You may not modify the terms of this User Agreement or any
of the policies or guidelines governing the Site without PPMC's express
prior written consent.
Third Party Links. The Site contains hyperlinks (or "links") to
Internet web sites of third persons and entities. PPMC provides such
links solely as a convenience to its Users. PPMC does not maintain and
is not responsible or liable for any off-Site web pages accessible from
or linked to the Site or any products, services or information
contained, offered or promoted therein. Your use of links to any third
person via the Site is at your own sole risk. You agree that the terms,
conditions and agreements governing the third person sites shall apply
to you when accessing such sites via a link from this Site, and you
agree to abide by such agreements. Links to off-Site web pages do not
necessarily constitute third person, sponsorship or affiliation of, with
or by PPMC and should not be construed as such. All opinions,
recommendations, views, news, information and other content contained in
any third person sites are solely those of the third persons, and PPMC
disclaims all responsibility and liability for such content.
Applicable Law. This User Agreement and all terms and conditions
included or incorporated by reference herein shall be governed by and
interpreted in accordance with the laws of the State of
New York applicable to agreements made and wholly performed therein.
You hereby consent to the exclusive jurisdiction of the Southern
District of New York or any New York State Court located in the Borough
of Manhattan, New York, in all disputes arising from or relating to this
User Agreement or your access to or use of the Site. You hereby waive
any objection to venue or inconvenient forum laid therein.
PPMC makes no claim that the Site may be lawfully viewed or
downloaded outside of the United States. Access to the materials may not
be legal by certain persons or in certain countries. If you access the
Site from outside of the United States, you do so at your own risk and
you are responsible for compliance with the laws of your jurisdiction.
YOU AND PPMC WILL SETTLE ANY DISAGREEMENTS BY ARBITRATION IN NEW YORK
STATE UNDER THE SUBSTANTIVE PROVISIONS OF NEW YORK STATE LAW.
With respect to the resolution of any such controversy, you further acknowledge that:
Arbitration is final and binding on the parties.
The parties are waiving their right to seek remedies in court, including the right to jury trial.
Pre-arbitration discovery is generally more limited than and different from court proceedings.
The arbitrators' award is not required to include factual findings or
legal reasoning and any party's right to appeal or to seek modification
of rulings by the arbitrators is strictly limited.
The panel of arbitrators will typically include a minority of
arbitrators who were or are affiliated with the securities industry.
Arbitration shall be conducted in the Borough of Manhattan, New York State.
Any questions about the nature of our relationship or the law
surrounding this relationship will be governed by New York State law
without giving effect to conflicts of law principles.
Entire Agreement. This User Agreement (including the Privacy Policy),
as modified from time to time, constitutes the entire agreement between
you and PPMC with respect to the subject matter hereof. This User
Agreement replaces all prior or contemporaneous understandings or
agreements, written or oral, regarding the subject matter hereof.
Joint Venture. Nothing in this User Agreement shall constitute or
create a joint venture, partnership, or any other similar arrangement
between you and PPMC. Neither party is authorized to act as agent or
bind the other party except as expressly stated in this User Agreement.
Assignability. This User Agreement will be binding on and will inure
to the benefit of the legal representatives, successors and assigns of
the parties hereto. PPMC may assign this User Agreement in whole or in
part at any time without your consent. You may not assign this User
Agreement or delegate any of your obligations hereunder. Any purported
assignment of this User Agreement in violation of its terms shall be
void.
Notice to PPMC. Any notice to PPMC that is required or permitted by
this User Agreement shall be in writing and shall be deemed effective
upon receipt, when sent by confirmed e-mail to info@paloma.com or when delivered in person or mailed by first class, registered or certified mail,
postage prepaid, to Paloma Partners Management Company, 2 American Lane,Greenwich, CT 06836-2571.
No Waiver of Rights. No failure of either party to enforce any of its
rights under this User Agreement will act as a waiver of such rights.
Enforceability. If any portion of any provision of this User
Agreement is found invalid or unenforceable, that provision shall be
enforced to the maximum extent possible and the remaining provisions of
this User Agreement shall remain in full force and effect.
Headings. Headings used in this User Agreement are for convenience
only. They do not constitute part of this User Agreement.