Theta Research, LLC, (Theta) gathers data on active Investment Managers and the active
strategies they use to manage money for their clients. It does so by compiling databases on the
transactions in tracking accounts which Theta monitors. This data is then made available by
subscription to interested parties who use the data to find Investment Managers (IM) and strategies
which meet their financial objectives. Additionally, Theta makes data available to academic
institutions and other parties for research purposes. The delivery of this data is subject to the
following privacy rules and restrictions.
Information regarding the ownership and titling of the tracking account and any other information
which is relevant to the ownership of the tracking account such as address, phone, or tax ID of the
owner is never released anytime to anybody. It is never seen by any entity outside of the
offices of Theta.
The underlying transaction data in the account is available for the IM’s review and may, at the IM’s
request, be made available to other parties who have a legitimate interest in seeing the data, such as
those who are performing due diligence on the IM for the purpose of using its services. By default,
this data is not made available, and only at the request of and with the permission of the IM will it be
made available to others in such a way that the transactions in the account can be identified with the
IM and/or its strategy.
Strategy information includes data such as securities traded in the account, average time fully in cash
and other data relative to the nature of the strategy. Performance data includes period performance,
volatility, and other calculations relative to the actual valuations of the account. These data are
published on the Theta Research website and made available to the IM and other interested parties
unless the IM requests in writing that such data not be included in performance rankings, model
listings or other reports available to Theta Research subscribers.
Theta recognizes the sensitive and personal nature of some of the data which it gathers. It seeks to
protect this information by only releasing and making available those data which the IM has agreed
to make public. Theta will never provide data to any entity it believes wishes to use the data to
reverse engineer a strategy or to use the data for any purpose other than to find an IM which it can
use to help meet its financial objectives.