Carson Private Capital together with its affiliates (“CPC” or the “Company”) is required by regulations promulgated by the Securities and Exchange Commission to adopt certain procedures designed to maintain and secure the nonpublic personal information of its potential, current and former investors from inappropriate disclosure to third parties.
CPC is committed to keeping personal nonpublic information collected from investors confidential and secure. The proper treatment of investors’ information is one of our highest priorities. The Company does not provide personal nonpublic information to unaffiliated solicitors for any purpose. The Company only keeps information that is necessary for it to provide the services requested by its investors and to administer/manage investors’ business with the Company.
Carson Private Capital is very concerned about the privacy of our investors. This notice summarizes our policies and practices in respect of the treatment of nonpublic personal information regarding our investors. The provisions of this policy apply to current and former investors and are subject to change.
- Nonpublic personal information is gathered from investors through subscription documents, questionnaires, certificates, tax forms, notices, and other forms of documentation provided by investors. Such information includes, without limitation: name; mail and email addresses; phone, mobile fax, and other contact numbers; social security number; driver’s license, passport or other identification numbers; date of birth; bank account numbers; wire transfer instructions; financial information; investment information; and other non-public personal information. This information may be received in any manner, including in-person discussions, telephone conversations, and electronic or other written communications.
- Nonpublic personal information about investors is not disclosed to anyone other than affiliates and “Service Providers” without permission, except as required or permitted by law (including, without limitation, as required pursuant to applicable United States and foreign open records laws and anti-money laundering laws). Service Providers include third parties that assist in providing services to CPC or investors, such as broker-dealers, bankers, lenders, transfer agents, custodians, accountants, auditors, attorneys, investment advisors, fund administrators and other professional service providers or consultants. Service Providers are expected to safeguard investors’ information by adhering to privacy policies consistent with those of CPC.
- Access to nonpublic personal information about investors is provided to those employees, agents, and/or Service Providers who need to know such information to provide services to the investors and/or CPC. Commercially reasonable physical, electronic, and procedural safeguards are maintained consistent with applicable industry standards. In addition, non-public personal information may be rendered unreadable or undecipherable by shredding or other means, including contracting with providers of such services.
- Notwithstanding the foregoing, CPC reserves the right to disclose nonpublic personal information about investors to any person or entity, including without limitation any governmental agency, regulatory authority or self-regulatory organization having jurisdiction over CPC or its affiliates, if (i) CPC determines in its discretion that such disclosure is necessary or advisable pursuant to or in connection with any United States federal, state or local, or non-U.S., law, rule, regulation, executive order or policy, including without limitation any anti-money laundering law and the PATRIOT Act and (ii) such disclosure is not otherwise prohibited by law, rule, regulation, executive order or policy.
- The policies and procedures described in this privacy notice with respect to nonpublic personal information obtained from investors continue to apply if services are no longer provided to such investors.
CPC reserves the right to change these policies and procedures at any time and will provide investors with a notice describing any such changes. Privacy policies will be sent to investors annually. If you have any questions about CPC’s privacy policies, please contact Greg Giannini, Chief Compliance Officer of Carson Private Capital, at (214) 999-1000 or via email at firstname.lastname@example.org.