What information do we collect from you and how is it used or disclosed?
When you visit the Firm website, our web service records details about your visit such as your IP address, the type of browser software you used, the date you logged in and what documents you accessed. Additionally we collect personal information from you in connection with our client onboarding and fund investment process. Such information includes, but is not limited to, your name, address, social security number, tax identification number, telephone number, email address, date of birth, personal financial information, personal documentation (passports, licenses, wills, organizational documents, etc.), banking and account details and employment information. We do not share your information with other parties for any purpose except those described herein and we do not sell or provide your information to any party for marketing purposes.
The Firm uses client personal data to perform advisory or legal services including processing transactions, maintaining accounts, client reporting and other client communications. This may involve the disclosure of your information to our affiliates and non-affiliated third parties involved in the day to day business transactions of your accounts and investments. The Firm respects all applicable laws and regulations in its use of your personal data.
Certain third party service providers who provide essential services to the Firm, such as the administration, development and maintenance of the Firm’s information technology systems and website, will have access to your personal data in the course of performing services for the Firm. The Firm ensures that these third parties are obligated to protect your privacy.
The Firm may also disclose your information to governmental agencies or entities, regulatory authorities, or other persons in line with any applicable law, regulations, court order or official request, or under any and for the purposes of any guidelines issued by regulatory or other authorities, or similar processes as either required or permitted by applicable law. You do not have the right, under Federal law, to opt out of the types of information sharing described above.
What security measures are in place to protect your non-public personal information?
The Firm has implemented reasonable physical, electronic and procedural security measures to protect your non-public personal data against unauthorized access, misuse, loss or destruction including but not limited to:
In addition to these measures, information on the Firm’s website is made available through a secure web browser with encryption technology that protects the transmission of your data from unauthorized access. Additionally a time-out feature is used to protect your data should your computer be left unattended after logging in or if you should be unable to exit a website by normal means. You should be aware that your emails to the Firm, however, may not be encrypted. You can contact the Firm to determine the most secure way for you to send us your sensitive information. The Firm will share all personal information with you by making it available on the Firm website or by email that has either been encrypted or contains password protected attachments.
In the event that any information under the Firm’s control is compromised as a result of a breach in our security, we will investigate the situation and take all reasonable steps, in accordance with applicable law and our internal incident response policies, to address the situation. Such steps may include notifying the affected individuals. The Firm will have will no liability or responsibility for any loss, unauthorized access or misuse of your personal information that result from an act or omission by you, including, but not limited to: i) failure to maintain the security of your password and username, ii) sending sensitive information to the Firm in an unsecure manner and iii) providing information or clicking on links contained in “phishing” emails that claim or appear to be from the Firm.
Updated: November 2015