Privacy Policy

The privacy of our investors is very important to us.

Set forth below are our policies with respect to personal information of subscribers, investors and former investors that we collect, use and disclose. In connection with the offering and sale of securities of the investment funds that we manage (the “Funds”), we collect and maintain personal information about subscribers.  We collect their personal information to enable us to provide them with services in connection with their investment in the Funds, to meet legal and regulatory requirements and for any other purpose to which they may consent in the future.  Their personal information is collected from the following sources:

  • subscription agreements or other forms that they submit to us;
  • their transactions with us and our affiliates; and
  • meetings and telephone conversations with them.

Unless a subscriber otherwise advises, by providing us with their personal information they have consented to our collection, use and disclosure of their information as provided herein.

We collect and maintain their personal information in order to give them the best possible service and allow us to establish their identity, protect us from error and fraud, comply with the law and assess their eligibility in our products.

We may disclose their personal information to third parties, when necessary, and to our affiliates in connection with the services we provide related to their subscription for securities of the Funds, including:

  • financial service providers, such as banks and others used to finance or facilitate transactions by, or operations of, the Funds;
  • other service providers to the Funds, such as accounting, legal, or tax preparation services; and
  • taxation and regulatory authorities and agencies.

We seek to carefully safeguard their private information and, to that end, restrict access to personal information about them to those employees and other persons who need to know the information to enable the Funds to provide services to them. Each of our employees is responsible for ensuring the confidentiality of all personal information they may access.

Investors’ personal information is maintained on our networks or on the networks of our service providers. Personal information may also be stored on a secure off-site storage facility. An investor may access their personal information to verify its accuracy, to withdraw their consent to any of the foregoing collections, uses and/or disclosures being made of their personal information and may update their information by contacting us at:  Please note that an investor’s ability to participate in the Funds may be impacted should they withdraw their consent to the collection, use and disclosure of their personal information as outlined above.