This privacy policy explains the manner in which Gorelick Brothers Capital, LLC and its affiliates (together, "we", "our" or "us") collect, utilize and maintain nonpublic personal information about our investors, as required under U.S. federal legislation. This privacy policy only applies to nonpublic information of investors who are individuals (not entities).

 

We collect personal information about our investors mainly through the following sources:

 

Subscription forms, investor questionnaires and other information provided by the investor in writing, in person, by telephone, electronically or by any other means. This information includes name, address, nationality, tax identification number, and financial and investment qualifications; and

Transactions within Gorelick Brothers Capital, LLC and its affiliates, including account balances, investments and withdrawals.

We do not sell or rent investor information. We do not disclose nonpublic personal information about our investors to nonaffiliated third parties or to affiliated entities, except as permitted by law. For example, we may share nonpublic personal information in the following situations:

 

To service providers in connection with the administration and servicing of Gorelick Brothers Capital, LLC and its affiliates, which may include attorneys, accountants, auditors and other professionals. We may also share information in connection with the servicing or processing of our transactions;

To affiliated companies in order to provide you with ongoing personal advice and assistance with respect to the products and services you have purchased through us and to introduce you to other products and services that may be of value to you;

To respond to a subpoena or court order, judicial process or regulatory authorities;

To protect against fraud, unauthorized transactions (such as money laundering), claims or other liabilities; and

Upon consent of an investor to release such information, including authorization to disclose such information to persons acting in a fiduciary or representative capacity on behalf of the investor.

Our policy is to require that all employees, financial professionals and companies providing services on our behalf keep client information confidential.

 

We maintain safeguards that comply with U.S. federal standards to protect investor information. We restrict access to the personal and account information of investors to those employees who need to know that information in the course of their job responsibilities. Third parties with whom we share investor information must agree to follow appropriate standards of security and confidentiality.

 

Our privacy policy applies to both current and former investors. We may disclose nonpublic personal information about a former investor to the same extent as for a current investor.

 

We may make changes to its privacy policy in the future. We will not make any change affecting you without first sending you a revised privacy policy describing the change.

 

Effective Date: 2003

 

Revised Date: June 2017