Our Commitment to Your Privacy: We are sensitive to the privacy concerns of our prospective, former and current investors. We are committed to protecting the confidentiality and security of information we collect about you. We are providing you with this notice to help you better understand why and how we collect certain personal information, the care with which we treat that information and how we use that information.
Gramm-Leach-Bliley Act: The Gramm-Leach-Bliley Act, as may be amended from time to time (“GLBA”), requires all “financial institutions,” defined to include investment advisers and investment companies, to establish procedures and systems to assure privacy of the personal and financial information of its “customers.” Strictly speaking, the GLBA requirements apply only to “customers” who are individuals. However, as a matter of practice the following procedures apply to the conduct of the Firm’s business generally and not with respect to information of only individual clients or investors.
Sources of Nonpublic Information: In connection with forming and operating our private investment Fund, we collect and maintain nonpublic personal information from the following sources:
- Information we receive from you in conversations over the telephone, in voicemails, through written correspondence, via email, in subscription agreements, investor questionnaires or other forms;
- Information about your transactions with us or others; and
- Information captured on our website, including registration information and any information captured via cookies, if any.
This information includes, without limitation, your address, social security number, assets, investment experience, transaction history, income and wire transfer instructions. If you are unsure as to whether information is nonpublic information, or as to the appropriate procedures to follow, you should contact our Firm’s Chief Compliance Officer.
Disclosure of Information: We do not knowingly disclose nonpublic personal information about you to any other person or entity except our employees, third party professional vendors who are provided access to such information in order to carry out our operations, or as otherwise required by law or regulation. These sharing practices are consistent with federal privacy and related laws, and in general, you may not limit the use of your personal information for these purposes under such laws. We note that the federal privacy laws only give you the right to limit the certain types of information sharing that we do not engage in (e.g., sharing with affiliates certain information relating to your transaction history or creditworthiness for their use in marketing to you, or sharing any personal information with non-affiliates for them to market to you).
Former Investors: We maintain nonpublic personal information of our former Investors and apply the same policies that apply to current investors.
Information Security: We consider the protection of sensitive information to be a sound business practice, and to that end we employ physical, electronic and procedural safeguards to protect your nonpublic personal information in our possession or under our control.
Further Information: We reserve the right to change our privacy policies and this Privacy Notice at any time. The examples contained within this notice are illustrations only and are not intended to be exclusive. This notice is intended to comply with the privacy provisions of applicable U.S. federal law. There may be additional rights under other foreign or domestic laws that apply to you. If you have any questions concerning this Privacy Notice, please contact the Chief Compliance Officer.