The Adviser will seek to limit its collection of Nonpublic Personal Information to that which is reasonably necessary for legitimate business purposes. The Adviser will not disclose Nonpublic Personal Information except in accordance with these policies and procedures, as permitted or required by law, or as authorized in writing by the Client or Fund Investor. The Adviser will never sell Nonpublic Personal Information.
With respect to Nonpublic Personal Information, the Adviser will strive to: (a) ensure the security and confidentiality of the information; (b) protect against anticipated threats and hazards to the security and integrity of the information; and (c) protect against unauthorized access to, or improper use of, the information. The CCO is responsible for administering these policies and procedures.
Nonpublic Personal Information may only be provided to third parties under the following circumstances:
- To broker-dealers or banks opening brokerage or bank accounts;
- To accountants, lawyers and others as directed in writing by Clients or Fund Investors;
- To specified family members as directed in writing by Clients or Fund Investors, or as authorized by law;
- To third-party service providers, as necessary to service Client or Fund Investor accounts; and
- To regulators and others, as required by law.