Altegris Winton Futures Fund, L.P. 10-K Cybersecurity GRC - 2025-03-26

Page last updated on March 26, 2025

Altegris Winton Futures Fund, L.P. reported their cybersecurity risk management and governance process in a yearly 10-K filed on 2025-03-26 17:23:51 EDT.

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10-K filed on 2025-03-26

Altegris Winton Futures Fund, L.P. filed a 10-K at 2025-03-26 17:23:51 EDT
Accession Number: 0001683168-25-001899

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Item 1C. Cybersecurity.

ITEM 1C: CYBERSECURITY RISK MANAGEMENT AND STRATEGY The Partnership’s cybersecurity risk management is established and governed by the General Partner. The General Partner establishes and implements cybersecurity risk management policies and procedures for the Partnership, and the Partnership relies on these established policies for cybersecurity risk management. The General Partner has policies for the proper use of information technology resources, as well as detect, prevent, and respond to cybersecurity threats that could jeopardize the privacy of client data and continuity of the General Partner and Partnership’s operations. The General Partner recognizes the importance of assessing, identifying, and managing material risks associated with cybersecurity threats, as defined in Item 106(a) of Regulation S-K on behalf of the Partnership. The General Partner has identified reasonably foreseeable, internal and external, threats that could result in unauthorized disclosure, misuse, alteration or destruction of personal financial information of clients, customers, investors or associated persons of the General Partner (collectively “customers”), or to the General Partner’s systems and networks. In response to identified risks, hazards or threats to the security of customers’ information and to the General Partner’s information technology systems and networks, risk management practices have been implemented. The General Partner engages third parties to implement and assess the effectiveness of its information technology program, which encompasses cybersecurity risk management. The General Partner has engaged a third-party firm to provide IT managed services support. The services include the monitoring and support of all user and cloud-based devices and provides 24x7 service. The IT firm also sends regular phishing tests, and the General Partner conducts annual mandatory employee security awareness training. Additionally, the General Partner conducts diligence on third-party service providers at the beginning of any service relationship and on an ongoing, periodic relationship for the duration of the relationship. 11 Since the Partnership does not have its own board of directors or any board committees, the Partnership relies on the senior management oversight of the General Partner. Specifically, the General Partner’s Head of Operations and Chief Executive Officer coordinate the Information Security Program, in consultation with the Chief Compliance Office. Senior management may designate consultants or third-party firms to carry out activities necessary to implement the program. In 2024, there were no cybersecurity threats that have materially affected or are reasonably likely to materially affect the Partnership, its business strategy, results of operations or financial condition. Refer to the risk factor captioned “Cyberattacks and Any Failure to Comply with Related Laws Could Negatively Impact the Partnership.” in Part I, ITEM 1A. " Risk Factors " for additional description of cybersecurity risks and potential related impacts on the Partnership.

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