I. Collection
We collect Non-public, Personal Information about our clients to serve your investment needs, provide customer service, offer new products and services and comply with legal and regulatory requirements. In particular, we collect information to help us determine which products and services you are eligible for and which products and services are suitable for you. The type of Non-public, Personal Information we collect from clients may include the following:
• name,
• address,
• telephone number,
• information regarding existing securities accounts,
• educational and employment history,
• prior investment experience with different types of investment vehicles, and any relationships a client may have with others involved in the securities business,
• social security number, and
• financial status (assets and income).
We collect this information about you from the following sources:
• the documents you deliver to us, such as application forms (including subscription documents),
• transactions with us and our affiliates in which you participate, and
• correspondence and other communications (including telephone, mail and e-mail) with you.
II. Confidentiality and Security
Except as described below, access to non-public information about clients, former clients and prospective clients is restricted to our employees who need to know that information in order to provide products or services to you. Those employees with access to Non-public, Personal Information are required to protect the confidentiality of that information. We maintain physical and procedural safeguards to protect your Non-public, Personal Information.
III. Uses of Information
For clients that are investors in our private investment vehicles, we use this information internally to process subscriptions and
provide customer service. For managed account clients, we use this information internally to provide advisory services to clients, to open an advisory account and one or more securities brokerage accounts, to process transactions for client accounts, for account maintenance and otherwise to provide investment advisory services to our clients.
We may also provide Non-public, Personal Information (including each type of non-public information that we collect listed above) about our clients and former clients to:
• unaffiliated financial service providers, such as a broker-dealers, custodians or other firms that have a need for such information in order to service or process a financial product or service requested or authorized by you or who will maintain or service your account on our behalf,
• broker-dealers and other financial institutions in connection with determinations of eligibility to participate in initial public offerings,
• broker-dealers, issuers and their counsel in connection with determinations of eligibility and participation in private securities placements,
• our attorneys, accountants and auditors to the extent required by them to perform services for us,
• as permitted or required by federal state or local law, such as in response to a subpoena, to prevent fraud or to comply with an inquiry or other requirement of a governmental agency or regulator, and
• to an affiliate of ours whose privacy and confidentiality policy is at least co-extensive with ours.
In addition, we may provide Non-public, Personal Information that we collect from clients, former clients and prospective clients (including your name, address and telephone number) to unaffiliated third parties or joint marketers that provide marketing for our services and have entered into a contract with us in which such third party agrees to maintain the confidentiality of the disclosed information.
Many jurisdictions are in the process of changing or creating anti-money laundering, embargo and trade sanction, or similar laws, regulations, requirements or regulatory policies (whether or not with force of law) and many financial intermediaries are in the process of changing or creating responsive disclosure and compliance policies (collectively “AML Policies”). We may Non-public, Personal Information that we collect from clients, former clients and prospective clients in respect of AML Policies or information requests related thereto to relevant third parties.
We do not otherwise provide Non-public, Personal Information about clients, former clients or prospective clients to anyone without their consent.
This policy applies to Strattam, and to each private investment vehicle sponsored by Strattam or for which Strattam or any of its affiliates serves as general partner or in a similar capacity.
Please contact Strattam’s Chief Compliance Officer at swilliams@strattam.com with any questions regarding this notice.