We are committed to keeping the personal information collected from potential, current and former investors confidential and secure. The proper handling of non-public personal information is one of our highest priorities. We want to be sure that you know why we need to collect personal information from you. We also want to explain to you our commitment to protect the information you provide to us. We do not disclose non-public personal information about our investors or former investors to unaffiliated third parties other than described below.
We collect information about you (such as your name, address, tax identification number and bank account information) from the subscription documents, from our discussions with you, from documents and information that you may deliver to us and in the course of managing the fund. We may use this information to evaluate your eligibility to invest in the fund and in connection with managing the fund and your investment therein.
We may provide your non-public personal information to our affiliates and to firms that assist us in managing and operating the fund and have a need for such information, such as a broker, administrator or custodian. We do not otherwise provide information about you to outside firms, organizations or individuals except to our attorneys, accountants, administrators, auditors and as permitted or required by law or requested or approved by you. With your approval, we also may share information with your advisors, which can include your accountant and/or attorney. In the normal course of our business, we may disclose information we collect about you to unaffiliated companies or individuals that contract with us to perform servicing functions such as:
- Record keeping and other administrative services
- Computer related services; and
- Good faith disclosure to regulators who have regulatory authority over the Fund.
Companies we hire to provide support services are not authorized to use your personal information for their own purposes and are obligated to maintain confidentiality of such information. We limit their use of your personal information to the performance of the specific service we have requested. We do not provide your personally identifiable information to mailing list vendors or solicitors for any purpose. When we provide personal information to a service provider, we expect these providers to safeguard your information, use the information only for the intended purposes and abide by applicable law.
Employee Access to Information
Only employees with a valid business reason have access to your personal information. These employees are educated on the importance of maintaining the confidentiality and security of this information. They are required to abide by our information handling practices.
Protection of Information
We maintain security standards to protect your information, whether written, spoken or electronic. We update and test our systems to ensure the protection and integrity of information.
Maintaining Accurate Information
Our goal is to maintain accurate, up-to-date investor records in accordance with industry standards. When you or any other investor provides us with updated information, we will endeavor to update our records as soon as possible. We do not, however, have a duty to inquire as to the changes in the information you provide to us.
Should you send us your questions and comments via e-mail; we will share your correspondence with those employees or agents most capable of addressing your questions and concerns. We will retain your communication until we have attempted to provide you with a complete and satisfactory response. Ultimately, we will either discard your communication or archive it according to the requirements under applicable securities laws. Please note that, unless we expressly advise you otherwise, our e-mail facilities do not provide a means for completely secure and private communications between us and yourself.
Although every attempt will be made to keep your information confidential, from a technical standpoint, there is still a risk. For that reason, please do not use e-mail to communicate information to us that you consider to be confidential. If you wish, you may contact us instead via telephone or by facsimile. Additional security is available to you if you equip your internet browser with 128-bit secure socket layer encryption, which provides more secure transmissions.
We recognize and respect the privacy concerns of potential, current and former investors. We are committed to safeguarding this information. As a member of the financial services industry, we are sending you this Privacy Notice for informational purposes and will update and distribute it as required by law. It is also available to you upon request.