Notice Regarding Privacy of Financial Information
Pursuant to the Gramm-Leach-Bliley Act and related rules regarding the Privacy of Consumer Financial Information, institutions that provide certain financial products or services to individuals to be used for personal, family, or household purposes are required to provide written notice to their customers regarding disclosure of nonpublic personal information. This notice is being provided to you to comply with these rules and so that you will know the type of information we collect about you and the circumstances under which that information may be disclosed to third parties.
In order to accurately and efficiently conduct each fund’s investment program, we must collect, maintain, use and disclose certain non-public information about you and our funds’ other investors. We understand that it is our obligation to maintain the confidentiality of information with regard to our individual investors generally. As a consequence, we do not disclose any nonpublic personal information about you to anyone other than:
- our affiliates and service providers as described further below; or
- other unaffiliated companies or persons for our everyday business purposes, such as to process transactions and maintain accounts, or as otherwise permitted or required by law.
In addition, consistent with industry practice, the provisions of our fund agreements and related agreements and the laws of the jurisdictions under which our funds are formed, we may distribute certain personally-identifiable financial information about you such as your name, the amount of your capital commitment and the amount of your capital contributions, to all investors in each specific fund.
We restrict internal access to nonpublic personal information about you to those employees who need to know that information to provide services to the fund and its investors. We maintain physical, electronic, and procedural safeguards to guard your nonpublic personal information. In addition, we will continue to assess new technology for protecting information with regard to our investors.
We collect, and may disclose to our affiliates and to service providers that we use in connection with the formation, administration and operation of our funds (e.g., our attorneys, accountants and auditors and third party administrators and recordkeepers for the funds), on a “need to know” basis, certain nonpublic personal information about you from the following sources:
- Information we receive from you as set forth in your subscription agreement, investor questionnaire or similar forms, such as your name, address, and social security or tax identification number; and/li>
- Information about your transactions with us, our affiliates and service providers, such as your participation in our funds, your capital account balance, capital commitment, capital contributions and distributions and, in the case of an investor that is an individual retirement account, information with regard to such account.
In connection with fundraising efforts for future funds, we may disclose information about existing investors to one or more placement agents for use in marketing efforts, including communication with prospective future investors. If we have your consent, we may also share your personal information with entities other than our affiliates, investors, service providers and employees.
This notice applies to all of the Fisher Lynch Capital, LLC sponsored funds. (rev. Apr. 2018)