We have adopted this Privacy Notice with recognition that protecting the privacy and security of the nonpublic personal information we obtain about our investors is an important responsibility. We do not disclose nonpublic personal information about our investors or former investors to third parties other than as described below. For purposes of this Privacy Notice, a “Client” shall mean to include any Investor of the Fund.
WHAT INFORMATION WE COLLECT
We collect nonpublic personal information about a Client (such as name, address, social security number, tax ID number, assets, income, investment objectives and experience, transaction history, wire instructions etc.) through various means. For example, we may collect this information through communication with a Client, from documents a Client delivers to us and in the course of providing investment advisory services to the Client.
HOW WE USE THIS INFORMATION
We may use the nonpublic personal information we collect from the Client for our everyday business purposes. These purposes may include providing investment advisory services to the Client, opening an account for the Client, processing transactions for the Client account, marketing products and services to the Client, or otherwise in furtherance of our business.
WHAT INFORMATION WE DISCLOSE
We may provide the Client’s nonpublic personal information to our affiliates and to firms that assist us in servicing the Client account, such as a broker or fund administrator. We may also disclose such information to service providers and financial institutions with whom we have joint marketing arrangements (i.e., a formal agreement between nonaffiliated financial companies that together market financial products or services to the Client, such as placement agents). We require third-party service providers and financial institutions with which we have joint marketing arrangements to protect the confidentiality of the Client’s information and to use the information only for the purposes for which we disclose the information to them. We do not otherwise provide information about the Client to outside parties, except to our attorneys, accountants and auditors and as permitted by law.
OPTING OUT
These above sharing practices are consistent with Federal privacy and related laws, and in general, the Client may not limit our use of the Client’s personal information for these purposes under such laws. We note that the Federal privacy laws only give the Client the right to limit the certain types of information sharing that we do not engage in (e.g., sharing with our affiliates certain information relating to the Client’s transaction history or creditworthiness for their use in marketing to the Client, or sharing any personal information with non-affiliates for them to market to the Client).
SECURITY OF THE CLIENT INFORMATION
To protect the Client’s nonpublic personal information from unauthorized access and use, we use security measures that comply with Federal law. These measures include physical, electronic and procedural safeguards. In addition to Federal private and related laws, certain states have adopted consumer privacy laws that may be applicable to investment advisers with Clients who are residents of those states.
CHANGES TO OUR PRIVACY POLICY OR RELATIONSHIP WITH THE CLIENT
Our policy regarding obtaining and disclosing information may change from time to time. We will provide the Client notice of any material change to this policy before we implement the change.
WHO IS PROVIDING THIS POLICY NOTICE
This Privacy Notice is furnished to you by Saints Capital Services, LLC and its affiliated entities.
