Our Commitment to Your Privacy: We are sensitive to the privacy concerns of our clients. We are providing you this notice to help you better understand why and how we collect certain personal information, the care with which we treat that information and how we use that information.
Sources of Non-Public Information: In connection with providing services to you, we collect and maintain non-public personal information from the following sources:
- Information we receive from you during in person conversations, over the telephone/videoconference, in voicemails, through written correspondence, via email, or on subscription agreements, investor questionnaires, applications or other forms;
- Information about your transactions with us or others; and
- Information collected on our website.
Disclosure of Information: We do not disclose any non-public personal information about you to anyone, except as follows:
- as permitted by applicable law or regulation; and
- to service providers (e.g., attorneys, accountants, investment professionals, administrators and other professionals) in connection with providing services to you and in order to satisfy legal compliance requirements and any anti-money laundering related customer identification procedures required by any laws or regulations applicable to such entities.
Former Clients: We maintain non-public personal information of our former clients and apply the same policies that apply to current clients.
Information Security: We consider the protection of sensitive information to be a sound business practice, and to that end we employ administrative, technical, physical, procedural and electronic safeguards to protect your non-public personal information in our possession or under our control.
Retention and Deletion of your Non-Public Personal Information: We will keep your non-public personal information for as long as it is required by us. For example, we may require it for our legitimate business purposes, to perform our contractual obligations, or where law or regulation obliges us to. Some personal data will be retained after your relationship with us ends. We expect to delete your personal data (at the latest) once there is no longer any legal or regulatory requirement or legitimate business purpose for retaining your personal data.
California Residents: In respect of any California residents to whom the California Consumer Privacy Act of 2018 (the “CCPA”) applies, you have the right to request that we disclose to you (i) the categories of personal information (as such term is defined under the CCPA) we have collected about you over the past twelve (12) months, (ii) the categories of sources of such personal information collected over the past twelve (12) months, (iii) our business or commercial purpose for collecting or sharing such personal information, (iv) the categories of third parties with whom we share such personal information, (v) the specific pieces of personal information we collected about you, and (vi) if we sold or disclosed your personal information for a business purpose, two separate lists disclosing: (a) sales, identifying the personal information categories that each category of recipient purchased and for each category identified, the categories of third parties to whom we sold that particular category; and (b) disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained and for each category identified, the categories of third parties to whom we disclosed that particular category. We do not sell any of the personal information we collect about you to third parties. The foregoing rights may be exercised by you or your authorized agent by submitting to us a request that allows us to reasonably verify that you are the person to whom the personal data relates. Our contact details for submitting such verifiable requests are provided below. We will not discriminate against you for exercising any of your privacy rights. You have the right to request that we delete any of your personal information that we retain, subject to certain exceptions.