Privacy Notice

United States privacy laws require that we explain to you how we handle “nonpublic personal information.”  This is information that in the course of our relationship with you, we receive or develop about you.  It includes information you provide to us orally or on applications or other forms and information we develop about you in the course of providing our services to you, such as the amount and type of your assets that we manage and transactions we place on your behalf. As a general rule, we do not disclose this nonpublic personal information to others.

The Firm takes precautions to maintain the privacy of personal information concerning the Firm’s current and prospective investors, including you. Federal law requires the Firm to give you this privacy notice explaining how the Firm collects, shares and protects your nonpublic personal information.

The Firm collects your nonpublic personal information from the following sources:

  • Information the Firm receives from you in your subscription documents or other related documents or forms;
  • Information from your transactions with the Firm or its affiliates;
  • Information from your communications with the Firm (written, telephonic, in person, electronic or by any other means), including any update notices provided by you;
  • Information the Firm receives from your representatives, advisors, consultants or other financial institutions with whom we have a relationship and/or whom you may have authorized to provide such information to the Firm; and
  • Information about you that the Firm may receive from a consumer reporting agency.

The types of personal information collected and shared may include, without limitation, your Social Security Number or taxpayer ID, contact information, address or domicile, bank account information, information regarding your assets (with respect to qualification determinations), identity of beneficial owners and your transaction history.

The Firm does not disclose any nonpublic personal information about its prospective, current or former investors, except to its affiliates and certain non-affiliated companies, including, without limitation, the Funds’ administrator, legal counsel, independent accountants, credit facility lender and placement agent in connection with the Firm’s everyday business purposes. For example, the Firm may disclose your personal information when:

  • Approving and maintaining your investment in the Funds;
  • Processing transactions relating to your investment in the Funds;
  • Administering the Funds and processing its transactions;
  • Responding to court orders, legal investigations and regulatory authorities; or
  • Reporting to credit bureaus.


The Firm restricts access to your nonpublic personal information to only the Firm’s employees and agents who need to know or use that information in order to provide services to you or the Firm. When disclosing your information to affiliates and other non-affiliated companies as described above, the Firm will require such companies to protect the confidentiality of your nonpublic personal information and to use the information only for purposes for which it is disclosed to them.

To protect your personal information from unauthorized access and use, the Firm maintains physical, electronic and procedural safeguards that comply with federal standards. Your trust is our most important asset, and we are committed to safeguarding against the unauthorized use of, and access to, your nonpublic personal information.

If you have any questions regarding this policy, please contact Susan Vuong at