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 (the “FTC Privacy Rule”), 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. We have been advised that we may be subject to such requirement. This notice is being provided to you to comply with the FTC Privacy Rule.
We understand that it is our obligation to maintain the confidentiality of information with regard to our investors generally. 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 and as described in the following sentences. Consistent with industry practice (and the provisions of our fund agreements), we may distribute certain personally-identifiable financial information such as the names of investors, the amount of their capital commitments and capital account information, to all investors or prospective investors in each specific existing fund and in future funds. In addition, in order to accurately and efficiently conduct the fund’s investment program, we must collect, maintain, use and disclose certain non-public information about you and the Partnership’s other investors. Finally, we may disclose certain personally-identifiable financial information such as the names of investors and the amount of their capital commitments to the portfolio companies of the Partnership (including prior to the date of an investor’s admission to the Partnership). Furthermore, we may be required by law to provide to self-regulatory organizations, state governments and the federal government information about the identity of our investors as well as their individual receipts of income and gross proceeds pursuant to the Sections 1471-1474 of the United States Internal Revenue Code of 1986, as amended (or any corresponding provisions of succeeding law).
We collect, and may disclose to our affiliates and service providers (e.g., our attorneys, accountants, auditors, administrators, 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:
In connection with fundraising efforts for future 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. The policy may change from time to time, but you can always review our current policy by asking us for a copy.
