Investor Privacy Policy

Investor Privacy Notice

We are committed to maintaining the confidentiality and security of your nonpublic personal information. We are providing this privacy notice to you to help you understand how we use nonpublic personal information that you have provided to us for purposes of receiving financial products or services from us. Specifically, we wish to inform you as to how we collect, share and protect your nonpublic personal information.

How we collect your nonpublic personal information
We collect certain nonpublic personal information when you invest in a private fund advised by us. We collect this information through discussions we have with you, from documents that you may provide to us, and in the ordinary course of providing our financial products or services to you. This information may include, among other things, your name and address, Social Security or taxpayer identification number, date of birth, net worth, source of your subscription funds, income, employment information, wire transfer instructions, investment experience, and risk tolerance.

How we share your nonpublic personal information
We do not disclose any nonpublic personal information about our investors, including the categories of information listed above, to any affiliates or nonaffiliated third parties except as necessary for everyday business purposes (such as to process transactions for your account or in connection with the ongoing operations of any private fund in which you invest), as authorized by you, or as permitted or required by law. We may also disclose nonpublic personal information to the following nonaffiliated third party service providers in order for them to provide their services to us or the private funds we manage:
• administrators
• attorneys
• regulatory compliance consultant
• accountants

We require such nonaffiliated third parties to protect the confidentiality of your nonpublic personal information and to use the information only for the purposes for which it is disclosed to them. We do not disclose nonpublic personal information to third parties for joint marketing purposes.

How we protect your nonpublic personal information
We restrict access to your nonpublic personal information to those employees who need to know the information in order to provide products or services to you. To protect your nonpublic personal information, we maintain physical, electronic and procedural safeguards that comply with federal regulations to guard your information. We adhere to the policies and practices described herein regardless of whether you are a current or former investor.

Can you limit how we share your information?
Financial companies choose how they share nonpublic personal information, and federal law gives consumers the right to limit some but not all sharing. It is necessary for us to share your nonpublic personal information in order to effectively manage your account, and therefore, you cannot limit how we share your information. When you become an investor in any private fund that we advise, you acknowledge that any nonpublic personal information about you may be shared for the purposes described in this privacy notice.

If you have any questions concerning this privacy notice or how we collect, share or protect your nonpublic personal information, please call Wayne Marino at 212-823-0733 or email To the extent we collect personal information from you for any purpose other than providing financial products or services, please refer to the privacy notice available at Privacy Policy for information on how we collect and use such personal information.