This explains the manner in which we collect, utilize, and maintain nonpublic personal information about each of our prospective, existing or former investors (collectively, “Investors”). Our policy applies only to Investors who are individuals or to certain entities that are essentially “alter egos” of individuals (e.g., grantor trusts, IRAs, and similar individual self-directed estate planning or investment vehicles).
We respect our Investors right to privacy and we are committed to maintaining and safeguarding nonpublic information. To manage our Investment Manager’s Clients in a professional and efficient manner, certain affiliates must from time to time obtain and disclose certain nonpublic personal information about an Investor. To protect the confidentiality of such information while making the necessary disclosures, we have developed the security policies described below.
I. Information Collected
We collect nonpublic personal information about Investors from the following sources: (i) information received from Investors through subscription agreements, investor questionnaires, (ii) other documents, such as an Investor’s name, address, social security number, assets, income, employment and amounts or types of such Investor’s investments; and (iii) information about Investor(s) transactions with our Investment Manager’s Client(s) or an affiliate, their affiliates and others, such as an Investor’s capital account balance, other account data and participation in other investments.
II. Information Disclosed
We will only disclose nonpublic personal information to our affiliates and service providers as permitted by applicable law. In general, our affiliates; including our Investment Manager may share Investor nonpublic personal information with their affiliates (including those who are involved in the operation, service, administration or management of, or the sale of interests in a pooled investment vehicle advised by our Investment Manager) and to unaffiliated third party service providers, only as permitted by law. For example, our affiliates such as our Investment Manager may share nonpublic personal information it collects as described above in connection with the administration and operations of its Client(s) (including disclosure to attorneys, accountants, administrators, service providers or auditors).
III. Security Procedures
Any service provider receiving an Investor’s personal information will be authorized to use such information only to perform the services required of them on behalf of an Investment Manager’s Client and its affiliates and then only as permitted by applicable law. Our affiliates, including our Investment Manager, restrict access to non-public personal information to those employees who require access to provide services to our affiliates and Investors. Our Investment Manager maintains physical, electronic and procedural safeguards to guard Investor non-public personal information. An Investor’s right to privacy extends to all forms of contact with the Investment Manager and its Clients, including telephone, written correspondence and electronic media.
We are committed to safeguarding the nonpublic personal information of our Investors and will adhere to the foregoing policies for both current and former investors.