Collection of Investor Information
Personal information is collected about clients through written questionnaires, during face-to-face meetings and telephone calls. Therefore, clients provide personal information in writing, in person, by telephone, and/or electronically. Such information may include, but is not limited to, name, address(es), nationality, tax identification number, tax residence, government issued photo identification to include driver’s license, passport(s) or other official government identification card, financial stature and investment qualifications.
Disclosure of Non-public Personal Information
The Investment Manager and/or its affiliates does not sell or rent client information. Investment Manager will not disclose any non-public personal information about the client to third parties unless it is compelled to do so by law, or if the Investment Manager is given permission by the client to do so. The Investment Manager does not disclose non-public personal information about individuals to nonaffiliated third parties or to affiliated entities, except inconnection with transactions undertaken at the client’s request or on its behalf. For example, the Investment Manager may share non-public personal information about a client in the following situations:
- To service providers inconnection with the administration and servicing of the client’s account(s), which may include attorneys, accountants, auditors and other professionals.
- The Investment Manager may also share information in connection with the servicing or processing of client transactions;
- To affiliated companies in order to provide the client with ongoing professional advice and assistance with respect to the products and services the client may have purchased through the Investment Manager and to introduce a client to other products and services that maybe of value or interest to a client;
- To respond to a subpoena or court order, judicial process or regulatory authorities;
- To protect against fraud, unauthorized transactions (such as money laundering), claims or other liabilities; and
- Upon written consent of a client to release such information, including authorization to disclose such information to persons acting in a fiduciary or representative capacity on behalf of the client.
Protection of Investor Information
- Ensure the security and confidentiality of client records;
- Protect against anticipated threats to the security or integrity of client records; and
- Protect against unauthorized access to client records that could result in substantial harm or inconvenience to any client.