What kind of personal information do we have about you and where did we get it?
We collect nonpublic personal information about you from the following sources:
- Subscription forms, investor questionnaires and other information provided by you in writing, in person, by telephone, electronically or by any other means; and
- Transactions between you and a Fund, including account balances, investments and withdrawals/redemptions.
When do we disclose your personal information?
We may disclose nonpublic personal information about you as permitted by law and in the following circumstances:
- In connection with a proposed or actual sale, merger or transfer of all or a portion of our business;
- To protect or defend against fraud, unauthorized transactions (such as money laundering), law suits, claims or other liabilities;
- To service providers in connection with the administration and operations of a Fund, which may include attorneys, auditors, administrators, third party marketers or other professionals;
- To investment funds in which we invest in connection with anti-money laundering legislation;
- To process or complete transactions requested by you; and
- Upon your consent to release such information, including authorization to disclose such information to persons acting in a fiduciary or representative capacity on your behalf.
How do we protect your personal information?
We maintain physical, electronic, and procedural safeguards that comply with federal standards to safeguard your nonpublic personal information. In addition, within our organization, we restrict access to nonpublic personal information about you to those employees and agents of the Funds who need to know that information in the course of their job responsibilities.
What about former clients and investors?
Please contact Exponential’s Chief Compliance Officer, John Cattier, at email@example.com with any questions regarding this policy.