Privacy Policy

Our Commitment to Your Privacy

: We are sensitive to the privacy concerns of clients. We have a long-standing policy of protecting the confidentiality and security of information we collect about you. 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 engaging in the sale of private offerings, we collect and maintain non-public personal information from the following sources

  • Information provided by you on applications, investor questionnaires, subscription agreements or other forms. This may include, but is not limited to, the following: i) name;ii) address; iii) social security number; iv) date of birth; v) employment information; and vi) assets, income and other similar information.
  • Information about investments you make in private investment funds and/or income-based product contracts.
  • In some cases, we will collect information from consumer reporting agencies, such as your creditworthiness and credit history.

Disclosure of Information: We do not disclose any non-public personal information about you to anyone, except as permitted by law or regulation and to service providers.

  • Disclosure of Information to Government Agencies and Self-Regulatory Organizations: The Firm discloses non-public personal information to non-affiliated third parties as permitted or required by law. These parties include government/regulatory organizations such as the Internal Revenue Service and the Securities and Exchange Commission.
  • Disclosure of Information to Service ProvidersThe Firm also discloses non-public personal information about you to non-affiliated third parties who the Firm utilizes in connection with the servicing or processing of financial products or services requested by you. For example, we may provide information to our legal counsel. Any such recipients acting on our behalf are required to keep your personal information confidential.
  • Disclosure of Information to Affiliates: The Firm may disclose information, as permitted by law, with our affiliated companies. By sharing information about you with our affiliated companies, we can offer you a broader range of financial services, improve your experience with us and serve you more efficiently.
  • Disclosure of Former Customer Information: The Firm does not disclose non-public personal information about former customers, except as required by law.

Information SecurityThe Firm maintains physical, electronic, and procedural safeguards to guard your non-public personal information. We protect your account information by placing it on the secure portion of our database. Our servers have been enabled with certain technology to prevent unauthorized parties from viewing your non-public personal information. Access to your non-public personal information is limited to those employees who need to know that information to provide products or services to you. The Firm conducts internal audits of its business practices and procedures to protect your personal information.

Further InformationWe reserve the right to change our privacy policies and this Privacy Notice at any time. 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 applicable U.S. federal law. You may have additional rights under other foreign or domestic laws that may apply to you.