This Privacy Notice is being provided in accordance with the applicable requirements under the privacy and data protection laws that apply in the jurisdictions where we operate (collectively, the “Data Protection Laws”). Each Fund and the Investment Manager are considered to be data controllers in respect of any personal information we hold about you for the purposes of certain Data Protection Laws. This means that the Fund and the Investment Manager (alone or jointly, as applicable) determine the purposes and the means of the processing of your personal information. Kah Capital Management, LLC (“KCM”) are required to provide privacy notices to their clients informing them of (1) the categories of non-public personal information that KCM collects from its clients, (2) the non-public personal information that KCM shares with affiliated and unaffiliated parties, and (3) KCM’s general policies and procedures to protect non-public personal information.
KCM collects information from its clients through managed account agreements and subscription agreements and related forms, investor questionnaires, and other information provided by the client in writing, in person, by telephone, electronically or by any other means. Examples of such information include name, address, social security number, birth date, assets, income and investment experience. KCM also collects information from your transactions with KCM, such as account activity and balances.
KCM is committed to protecting clients’ non-public personal information and maintains administrative, technical and physical safeguards for the protection of such information. Access to physical and electronic records containing non-public personal information is restricted to our personnel who need to know that information in order to provide services to you.
In order to service your accounts and process your transactions, KCM will provide your non-public personal information to our affiliates and to firms that assist us in servicing your account and have a need for such information such as administrators. We require third party service providers to protect the confidentiality of your information.
KCM does not disclose any non-public personal information about our clients to anyone other than (1) in connection with the administration, processing and servicing of a client’s accounts as described above, (2) to our accountants, attorneys and auditors, or (3) as otherwise permitted or required by law.
KCM does not share non-public personal information with affiliated or unaffiliated third parties except under the circumstances noted above. Since sharing under such circumstances is necessary to service a client’s account or is permitted or required by law, clients cannot limit this sharing.
This privacy notice applies to KCM and each investment vehicle to which KCM serves as investment manager or investment adviser.