Pursuant to the Gramm-Leach-Bliley Act, Public Law No. 106-102, and the rule issued by the Federal Trade Commission regarding the Privacy of Consumer Financial Information, 16 C.F.R. Part 313, institutions that provide certain financial products or services to individuals to be used for personal, family or household purposes are required to provide written notices to their customers regarding disclosure of nonpublic personal information. This notice is being provided to you to comply with this requirement.
We understand that it is our obligation to maintain the confidentiality of information with regard to our investors. As a consequence, we do not disclose any nonpublic personal information about our investors or former investors to anyone other than our affiliates and service providers, except as permitted by law. However, in order to conduct accurately and efficiently the investment program of the investment funds that we manage, we must collect and maintain certain nonpublic information about you and the other investors in such funds.
We collect, and may disclose to our affiliates and service providers (e.g., our attorneys, accountants, entities that assist us with the distribution of stock to our investors and placement agents for future fundraising activities) 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
- Information about your transactions with us, our affiliates and service providers, or others, such as your participation in our investment funds, your capital account balance, contributions and distributions and, in the case of an investor that is an individual retirement account, information with regard to such account.
We restrict access to nonpublic personal information about you to those employees who need to know that information to provide services to the Fulcrum investment funds and investors therein. 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. If we have your consent, we may also share your personal information with entities other than our affiliates and service providers. In connection with fundraising efforts for future investment 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.