NOTIFICATION OF PRIVACY POLICIES AND PRACTICES
Maintaining the confidentiality of the personal information of our current and prospective investors is one of our highest priorities. This notice sets forth the type of personal information we collect, how that information is used by us, and how we protect your personal information.
HOW AND WHY WE COLLECT PERSONAL INFORMATION
Personal information may be collected from you in order to comply with legal and regulatory requirements. Information may be collected from any of the following sources:
a. From You: We collect information from you when you enter into a subscription agreement with a fund we manage. We may also collect information from investor questionnaires, W-9’s and other applications or forms that you complete. This information may include items such as your name, address, e-mail address, social security number, birth date, annual income, net worth, marital status, and investment risk tolerance. If you indicate you have a spouse or partner, his/her personal and financial account information may also be requested.
b. From Transactions: If you invest in a fund managed by us, we keep records relating to your interest in the fund.
c. From our Web Site: If you visit our website, we may collect your contact details and other information that you provide directly to us and we may track the amount of time you spend on our site, the parts of our site you visited and other technical information.
2. Use of Personal Information.
Your personal information is collected and maintained by us so that we may fulfill our legal and regulatory requirements.
DISCLOSURE OF PERSONAL INFORMATION
We do not, and do not intend, to disclose personal information about current or former investors to nonaffiliated third parties except as set forth below. If in the future this policy changes you will be notified and provided with an opportunity to opt out of such disclosure. We may share your personal information as follows:
a. We will reveal or share your personal information where the law permits or requires it, such as for tax reporting purposes or pursuant to a court order, or to otherwise comply with applicable laws and regulations.
b. We may reveal or share your personal information with our affiliates. Our affiliates include, for example, investment funds that we manage and over which we have control.
c. We may reveal or share your personal information with unaffiliated service providers such as brokers, fund administrators and transfer agents in connection with distributions or other transactions. Your personal information may also be provided to attorneys, accountants or auditors in order to enable us to comply with legal and regulatory requirements.
PROTECTION OF YOUR PERSONAL INFORMATION
Our employees may, from time to time, have access to your personal information in order to provide services to you. All employees are subject to the terms of our Privacy Policies and Practices. We also maintain physical, electronic and procedural safeguards designed to protect non-public personal financial information.