Privacy Notice

Our Commitment to Your Privacy:  We are sensitive to the privacy concerns of our individual investors and clients.  We have a long-standing policy of protecting the confidentiality and security of information we collect about you.  We are providing you with 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 forming and operating our private investment funds for our investors and providing other investment advisory services, we collect and maintain non-public personal information from the following sources: 

• Information we receive from you in conversations over the telephone, in voicemails, through written correspondence, via email, or in subscription agreements, investor questionnaires, applications, or other forms; 

• Information about your transactions with us or others; and 

• Information captured on our website, including registration information, and any information captured via “cookies.” 

Information Security:  We consider the protection of sensitive information to be a sound business practice, and to that end we employ physical, electronic, and procedural safeguards to protect your non-public personal information in our possession or under our control. 

Disclosure of Information:  Our policy is not to disclose any non-public personal information about you to anyone, except as permitted or required by law or regulation and to service providers, as required to provide services to you, or as otherwise authorized by you in writing. 

Former Investors:  We maintain non-public personal information of our former clients and investors and apply the same policies that apply to current clients and investors. 

Further Information:  We reserve the right to change our privacy policies and this Privacy Notice at any time.  We will notify you of any changes to our information disclosure policy that would expand the scope of recipients of your non-public information beyond those categories specified in this notice.  The examples contained within this notice are illustrations only and are not intended to be exclusive.  This notice is intended to comply with the privacy provisions of the Gramm-Leach-Bliley Act.  You may have additional rights under other foreign or domestic laws that may apply to you. 

This Privacy Notice is intended only for individuals and certain entities that are essentially “alter egos” of individuals
(e.g., revocable grantor trusts, IRAs or certain estate planning vehicles).