Maintaining the confidentiality
of the personal information of our current and prospective
customers is one of our highest priorities. This
notice sets forth the type of personal information
we collect, how that information is used by us,
and how we protect your personal information.
 HOW
AND WHY WE COLLECT PERSONAL INFORMATION ?
1. Collection.
Personal information may be collected from you in
order to offer or provide you with products or services,
process transactions on your behalf and comply with
legal and regulatory requirements. Information may
be collected from any of the following sources:
| a. |
From You:
We collect information from you when you request
information or services from us or enter into
an investment management agreement with us
or a subscription agreement with a fund we
manage. We may also collect information from
investor questionnaires, W-9’s and other
applications or forms that you complete when
requesting information or services from us.
This information may include items such as
your name, address, e-mail address, social
security number, birth date, annual income,
net worth, marital status, investment goals
and investment risk tolerance. If you indicate
you have a spouse or partner, his/her personal
and financial account information may also
be requested. |
| b. |
From Transactions: If
you obtain advice or services from us, we
keep records of the advice or service provided.
We keep records relating to items such as
your account balance, payment history, securities
positions and securities purchases and sales.
This enables us to provide you with a history
of your transactions with us and service your
account. |
| b. |
From our Web Site: If
you visit our website, we may use a so-called
cookie to track the amount of time you spend
on our site, the parts of our site you visited
and other technical information. We use this
information to improve the functionality of
our web site. |
2. Use of Personal Information
Your personal information is collected and maintained
by us so that we may develop, offer and deliver
products and services to you, process transactions
in your account and fulfill our legal and regulatory
requirements.
DISCLOSURE
OF PERSONAL INFORMATION
We do not, and do not intend, to sell or distribute
personal information about current or former customers
to nonaffiliated third parties except as set forth
below. If in the future this policy changes you
will be notified and provided with an opportunity
to opt out of such disclosure. We may share your
personal information as follows:
| a. |
We will reveal
or share your personal information where the
law requires it, such as for tax reporting
purposes or pursuant to a court order. |
| b. |
We may reveal or share
your personal information with our affiliates.
Our affiliates include, for example, investment
funds that we manage and over which we have
control. |
| b. |
We may reveal or share
your personal information with unaffiliated
service providers such as brokers, fund administrators
and transfer agents in connection with processing
transactions for your account. Your personal
information may also be provided to attorneys,
accountants or auditors in order to enable
us to provide requested services to you and
to comply with legal and regulatory requirements. |
PROTECTION
OF YOUR PERSONAL INFORMATION
Our employees may, from time to
time, have access to your personal information in
order to provide services to you. We restrict access
to nonpublic personal financial information to those
employees who need to know that information in order
to provide you with products and services. All employees
are subject to the terms of our Company’s
compliance manual, which requires employees to treat
confidentially all information obtained from or
about you or your account. We also maintain physical,
electronic and procedural safeguards designed to
protect nonpublic personal financial information.
|
