Privacy Notice Of HM Capital Partners LLC
To facilitate the protection of confidential nonpublic personal information obtained from investors, HM Capital Partners LLC and its affiliates (together, “HM”) have developed internal policies and procedures with respect to the treatment of such nonpublic personal information.
1. Nonpublic personal information is gathered from investors through subscription documents, questionnaires, certificates, tax forms, notices, and other forms of documentation provide by investors. Such information includes, without limitation: name; mail and email addresses; phone, fax, and other numbers; social security number; driver’s license, passport or other identification numbers; account numbers; wire transfer instructions; financial information; investment information; and other personal information. This information may be received in any manner, including in-person discussions, telephone conversations, and electronic or other written communications.
2. 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 investors, such as broker-dealers, bankers, lenders, transfer agents, custodians, accountants, auditors, attorneys, investment advisors, fund administrators and other professional service providers or consultants.
3. Access to nonpublic personal information about investors is provided to those employees, agents, and Service Providers who need to know such information to provide services to the investors or HM. Commercially reasonable physical, electronic, and procedural safeguards are maintained consistent with applicable standards. In addition, nonpublic personal information may be rendered unreadable or undecipherable by shredding or other means, including contracting with providers of such services.
4. Notwithstanding the foregoing, HM 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 HM or its affiliates, if (i) HM 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.
5. 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. HM 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 the investors annually.
If you have any questions about the privacy policies, please call Jerry Neisel at 214-740-7350.