Information the Adviser Collects
The Adviser collects nonpublic personal information from the following sources: (i) information received on applications and other forms including subscription documents for private investments, investment advisory agreements, and questionnaires, which information may include name, address, social security number, income, net worth, asset statement, tax circumstances, investment experience, investment goals and risk tolerance; (ii) information about transactions with the Adviser and others such as other products purchased, information about additions and withdrawals, parties to a transaction, positions held or sold and pricing; and (iii) correspondence (written, telephonic or electronic), including information obtained from third parties such as brokers.
“Nonpublic personal information” is nonpublic information that is obtained in connection with the provision of a financial product or service for personal, family or household purposes.
Information the Adviser Discloses
The Adviser does not disclose any nonpublic personal information that it collects to unaffiliated third parties except to certain service providers or as is expressly permitted by a client or by law. The Adviser treats nonpublic personal information concerning the Adviser’s former clients the same way it treats such information about current clients. The Adviser does not sell any personal information about clients to any third party.
In the normal course of business, personal information collected, as described above, may be shared with nonaffiliated third party service providers as necessary to (i) effect, administer or enforce a transaction that a client may request or authorize; (ii) in connection with processing or servicing a financial product or service that a client may request; or (iii) in connection with maintaining or servicing a client’s account with the third party. For example, information may be disclosed to others to enable them to perform general administrative activities, to assist in processing a transaction authorized or requested by a client or to coordinate with a custodian.
Protecting Confidentiality and Security
The Adviser maintains physical, electronic and procedural safeguards to protect the nonpublic personal information they have about clients. They treat this information in a confidential manner, and restrict access to nonpublic information to employees who have an appropriate reason to access it, such as for administration or to offer products and services. The Adviser educates employees on the importance of protecting the privacy and security of confidential personal information. In addition, they require third parties with whom they share information to:
- maintain policies and procedures designed to assure only appropriate access to, and use of information about, clients; and
- maintain physical, electronic and procedural safeguards that comply with federal standards to guard nonpublic information of clients.