III. Collection of Information
AAF may possess non-public personal information about Clients and investors to serve investment needs, provide customer service, and comply with legal and regulatory requirements. The type of non-public personal information AAF may possess may include the following:
• Telephone numbers,
• Information regarding existing accounts,
• Financial status as it relates to qualifying for an investment in a private fund managed by AAF (e.g. assets and income).
ALTERNATIVE ACCESS FUNDS, LLC
AAF collects this information from the following sources:
• The documents delivered in connection with making an investment in a private fund managed by AAF, including subscription documents,
• Transactions with AAF and its affiliates in which the Client or investor participates,
• Correspondence and other communications (including telephone, mail, and e-mail).
IV. Opt Out Right
V. Confidentiality and Security
Except as described below, access to non-public information about existing, former, and prospective clients and private fund investors is restricted to AAF employees who need to know that information in order to provide products or services to Clients or investors. Those employees with access to non-public personal information are required to protect the confidentiality of that information. AAF maintains physical and procedural safeguards to protect non-public personal information.
VI. Physical Safeguard Procedures
1. When in use, Client and private fund investor information will not be left unattended,
2. AAF’s office is located in a secured building and is locked off hours to prevent unauthorized entry onto the premises,
3. Physical access to AAF’s office is limited to authorized personnel only and any visitors will remain escorted at all times,
4. Any hard copy documents containing Client and private fund investor information that are not to be retained will be disposed of promptly.
VII. Electronic Safeguard Procedures
1. All computers with access to Client and investor information are password protected and have active and current anti-virus, anti-spyware, and firewall protection,
2. When not in use, all computers will be locked in screen saver mode.
VIII. Anti-Identity Theft Procedures
In addition to complying with procedures above regarding safeguarding of non-public personal information, AAF will only transfer funds to investor accounts that are in the name of the investor of record and, in the case of wire transfers, to such investor’s account as identified upon the opening of the account. No payment of any investor funds will be knowingly sent to any third party, and AAF’s financial or accounting personnel will report suspicious requests for third-party payments or changes to investor account or wire information to the CCO.
IX. Uses of Information
Investor non-public personal information may be used internally by employees of AAF to process subscriptions and provide services to such investors or the private funds in which they are invested.
AAF may also provide non-public personal information about its prospective, existing, and former Clients and private fund investors to the following:
• Unaffiliated financial service providers, such as a broker-dealers, custodians, or other firms that have a need for such information in order to service or process a financial product or service requested or authorized by such Client or private fund investor or who will maintain or service such Client or private fund investor’s account on AAF’s behalf,
• Broker-dealers, issuers of securities, and their counsel in connection with determinations of eligibility and participation in private securities placements,
• Attorneys, accountants, and auditors retained by AAF, to the extent required by them to perform services for AAF and its Clients,
• As permitted or required by federal, state, or local law, such as in response to a subpoena, to prevent fraud, or to comply with an inquiry or other requirement of a governmental agency or regulator,
• To an affiliate of AAF whose privacy and confidentiality policy is at least co-extensive with AAF.
Many jurisdictions are in the process of creating or changing anti-money laundering, embargo and trade sanction, or similar laws, regulations, requirements or regulatory policies (whether or not with force of law) and many financial intermediaries are in the process of creating or changing responsive disclosure and compliance policies (collectively “AML Policies,” which are further described in AAF’s Compliance Manual). AAF may provide non-public personal information collected from Clients, former Clients, and prospective Clients in respect of AML Policies or information requests related thereto to relevant third parties.