Our Commitment to Your Privacy: We are sensitive to the privacy concerns of our prospective, former and current individual Clients and Fund Investors of an ILS Capital Fund. We have a long-standing policy of protecting the confidentiality and security of information we collect about you. We are providing you with 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.
Gramm-Leach-Bliley Act: The federal Gramm-Leach-Bliley Act, as may be amended from time to time (“GLBA”), requires all “financial institutions,” defined to include investment advisers and investment companies, to establish procedures and systems to assure privacy of the personal and financial information of its “customers.” Strictly speaking, the GLBA requirements apply only to “customers” who are individuals. However, as a matter of practice the following procedures apply to the conduct of the Firm’s business generally and not with respect to information of only specific Clients or Fund Investors.
Sources of Non-Public Information: In connection with forming and operating our private investment funds for our investors, we collect and maintain non-public personal information from the following sources:
- Information we receive from you in conversations over the telephone, in voicemails, through written correspondence, via email, in subscription agreements, investor questionnaires or other forms; and
- Information about your transactions with us or others.
Disclosure of Information: We do not knowingly disclose non-public personal information about you to any other person or entity except our employees, third-party professional Vendors who are provided access to such information in order to carry out our operations, or as otherwise required by law or regulation. These sharing practices are consistent with federal privacy and related laws, and in general, you may not limit the use of your personal information for these purposes under such laws. We note that the federal privacy laws only give you the right to limit the certain types of information sharing that we do not engage in (e.g., sharing with affiliates certain information relating to your transaction history or creditworthiness for their use in marketing to you, or sharing any personal information with non-affiliates for them to market to you).
Former Clients: We maintain non-public personal information of our former investors and apply the same policies that apply to current investors.
Information Security: We consider the protection of sensitive information to be a sound business practice, and to that end we employ physical, electronic and procedural safeguards to protect your non-public personal information in our possession or under our control.