PRIVACY POLICY
Regulation S-P, the Gramm-Leach-Bliley Act, and regulations promulgated thereunder, require certain organizations to follow rules regarding the private, nonpublic information of investors. Maintaining the confidentiality of private, nonpublic information is important to GEM (the “Firm”). The following sets forth the Firm’s policies with respect to the private, nonpublic information of prospective investors and current and former investors of Firm-managed funds (“Managed Funds”). These policies may be changed at any time, provided that notice of such changes is given to investors.
Investors provide the Firm and/or the Firm’s agents (such as a fund administrator) with personal information, including address, social security number, employer identification number, assets and/or income information, (i) in Subscription Agreements and related documents, (ii) in correspondence and conversations with the Firm’s agents, and (iii) through transactions with the Firm and its Managed Funds.
The Firm will not disclose any of this personal information about prospective investors or current and former investors to anyone, except as permitted or required by law. For example it may be necessary, under anti-money laundering and similar laws, to disclose information about investors in connection with U.S. Office of Foreign Asset Control (“OFAC”) compliance efforts. The Firm also may release information to the custodian and fund administrator for OFAC compliance, as well as anti-money laundering and “know your client” review processes, to complete transactions and to provide administrative services to prospective investors, or current or former investors. In addition, the Firm will release information about a prospective, current or former investor if the investor directs the Firm to do so.
The Firm seeks to safeguard private, nonpublic information given to it and, to that end, restricts access to such information about prospective investors and current and former investors to those employees, agents and others who need to know the information to enable the Firm to conduct its business.
The Firm maintains physical, electronic, and procedural safeguards to protect private, nonpublic information given to it. Physical copies of information, including original subscription documents, are maintained in a locked storage room with controlled access. Electronic information is maintained both in a secure server room with controlled access, and in a secure server housed offsite from the Firm’s office. Conventional, electronic, and biometric locks protect this facility.
The Firm will provide each investor with initial notice of the Firm’s current privacy policy (“Privacy Notice”) when the investor relationship is established. Generally, this occurs at the time of distribution of the private placement memorandum. The Firm will also provide each investor with a new notice of the Firm’s current privacy policies at least annually, in August of each year. The Firm does not disclose information to unaffiliated third parties in a manner that would require the provision of “opt-out” notices to investors.
An illustrative example of the Privacy Notice sent to investors is attached to this policy.
GLOBAL ENDOWMENT MANAGEMENT PRIVACY NOTICE
An investor’s privacy is very important to Global Endowment Management, LP (“GEM” or the “Firm”). This Privacy Notice sets forth the Firm’s policies with respect to nonpublic personal information of prospective investors and current and former investors in the GEM funds (“Managed Funds”). These policies may be changed at any time, and a notice of such change will be given to investors.
Prospective investors and current and former investors provide the Firm and/or the Firm’s agents, such as its fund administrator, with personal information, including address, social security or tax identification number, assets and/or income information, (i) in Subscription Agreements and related documents, (ii) in correspondence and conversations with the Firm’s agents, and (iii) through transactions with the Firm.
The Firm will not disclose any of this personal information about prospective investors and current and former investors to anyone, except our agents, attorneys and accountants, and as permitted or required by law. For example, it may be necessary, under anti-money laundering and similar laws, to disclose information about prospective investors or current or former investors in connection with anti-money laundering and OFAC compliance efforts. The Firm also may release information to complete transactions and to provide administrative services to prospective investors or current or former investors. In addition, the Firm will release information about a prospective investor or current or former investor if such investor directs the Firm to do so.
The Firm safeguards private information given to it and, to that end, restricts access to nonpublic personal information about prospective investors and current and former investors to its employees, agents and others who need to know the information to enable the Firm to provide services to prospective investors and current and former investors. The Firm maintains physical, electronic, and procedural safeguards to protect nonpublic personal information given to it.
