The Firm is required to collect private financial information about its customers and prospective customers to satisfy its “know your customer” obligation. In the course of handling an investor’s subscription or redemption in a Client Fund, the Firm will know what transactions have been effected and other information about the financial circumstances of the investor. It is the Firm’s policy not to disclose this type of information except under the following circumstances:
- as requested or instructed by the underlying investor;
- to personnel of the Firm, to enable them to provide services to the investor;
- to third-party service providers to enable them to provide services necessary to carry out the instructions of underlying investors or the Firm’s obligations to investors;
- to facilitate the processing of transactions for customers;
- as required by law, for example, in response to an inquiry by the SEC, the NFA or a court subpoena;
- to the Firm’s legal counsel, or to its independent auditor, as may be required for audit purposes.
The Firm does not sell investor lists or otherwise share them with third parties… Accordingly, customers are not offered to opt-out of any sharing of customer information. These policies apply to former and current investors, and to persons who have submitted information to the Firm with a view to entering into a business relationship with the Firm.
The Firm will send a notice of its policies with respect to confidential treatment of non-public personal information as follows:
- to each new customer at the time a new investor Account is opened;
- to each existing underlying investors annually with the second quarter mailing if any material changes have been made; and
- to each underlying investor when the Firm sends the underlying investor a form requesting confidential financial information.
Restrictions on Supervised Persons.
Supervised Persons of the Firm must not disclose any private financial information about an investor (including Firm employee investors) to any other firm or person, except as permitted by the policy stated above. All employees must safeguard confidential information about investors, potential investors, or employees, and their accounts (including profit data, credit information, financial condition, and business transactions).